https://www.taxtmi.com/caselaws?id=776191 The ITAT Delhi upheld the assessee's cost allocation method based on headcount ratio, rejecting the TPO's substitution with salary expense ratio due to lack of new evidence and failure to select comparables, consistent with prior rulings. Disallowance of CSR expenditure under section 80G was set aside, recognizing CSR as philanthropic and eligible for deduction if other conditions are met. The tribunal also directed the AO to allow depreciation at 25% on intangible assets, following precedent in the assessee's earlier years. All related appeals were allowed, and disallowances were deleted. en-us Thu, 31 Jul 2025 00:00:00 +0530 Mon, 04 Aug 2025 10:59:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776191 The ITAT Delhi upheld the assessee's cost allocation method based on headcount ratio, rejecting the TPO's substitution with salary expense ratio due to lack of new evidence and failure to select comparables, consistent with prior rulings. Disallowance of CSR expenditure under section 80G was set aside, recognizing CSR as philanthropic and eligible for deduction if other conditions are met. The tribunal also directed the AO to allow depreciation at 25% on intangible assets, following precedent in the assessee's earlier years. All related appeals were allowed, and disallowances were deleted. Case-Laws Income Tax Thu, 31 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776191