Court Upholds TPO's Cost Allocation Method Based on Direct Costs; Emphasizes Assessee's Duty to Provide Justifying Details.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....TP Adjustment - Allocation of Common Cost - we agree with the TPO’s calculation of allocation based on the direct cost as it is the best suitable basis for allocation of Common Cost of G&A. Because the direct cost is easily available and verifiable. The onus is always on the assessee to file all necessary details before the TPO to prove the allocation - AT....