https://www.taxtmi.com/caselaws?id=446299 ITAT Pune dismissed assessee's appeal on transfer pricing adjustments for common cost allocation. The tribunal upheld TPO's allocation based on direct cost rather than technical manpower ratio, finding assessee's method conceptually flawed for general administrative expenses. Several comparables were excluded from benchmarking analysis including Exilant Technologies, E-Infochips, Nihilent, Cybage Software, and Ninestars due to functional dissimilarity, extraordinary events, or incomplete data. Entity-level PLI was rejected as 90% transactions were with non-associated enterprises. Section 14A disallowance was deleted as AO failed to record satisfaction. Additional deduction claim under section 90 was remanded for fresh verification. en-us Thu, 02 Nov 2023 00:00:00 +0530 Wed, 29 Nov 2023 11:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446299 ITAT Pune dismissed assessee's appeal on transfer pricing adjustments for common cost allocation. The tribunal upheld TPO's allocation based on direct cost rather than technical manpower ratio, finding assessee's method conceptually flawed for general administrative expenses. Several comparables were excluded from benchmarking analysis including Exilant Technologies, E-Infochips, Nihilent, Cybage Software, and Ninestars due to functional dissimilarity, extraordinary events, or incomplete data. Entity-level PLI was rejected as 90% transactions were with non-associated enterprises. Section 14A disallowance was deleted as AO failed to record satisfaction. Additional deduction claim under section 90 was remanded for fresh verification. Case-Laws Income Tax Thu, 02 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446299