https://www.taxtmi.com/caselaws?id=456143 Common employee costs reimbursed to an associated enterprise were accepted as allocable on a head-count basis because the shared finance, administration and human resource functions were run through common staff on a cost-to-cost basis. An ad hoc 30% disallowance was unsustainable where the transfer pricing authority had accepted the transaction at arm's length and no contrary material justified replacing the chosen allocation method with estimation. Amounts recovered from group entities for circuit and related charges were treated as reimbursements of common expenses, not as royalty or fees for technical services, because the receipts were on a cost-to-cost basis and the same factual treatment had been accepted earlier. The additions were therefore deleted. en-us Tue, 25 Feb 2020 00:00:00 +0530 Tue, 02 Jul 2024 19:57:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456143 Common employee costs reimbursed to an associated enterprise were accepted as allocable on a head-count basis because the shared finance, administration and human resource functions were run through common staff on a cost-to-cost basis. An ad hoc 30% disallowance was unsustainable where the transfer pricing authority had accepted the transaction at arm's length and no contrary material justified replacing the chosen allocation method with estimation. Amounts recovered from group entities for circuit and related charges were treated as reimbursements of common expenses, not as royalty or fees for technical services, because the receipts were on a cost-to-cost basis and the same factual treatment had been accepted earlier. The additions were therefore deleted. Case-Laws Income Tax Tue, 25 Feb 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456143