TP Adjustment - ITAT upheld cost allocation using 'headcount' for support services. Pricing at Arm's Length. No adjustments made for consistency.

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....The Appellate Tribunal examined Transfer Pricing Adjustment disallowing cost of support services. The cost allocation key based on 'headcount' was accepted by the Transfer Pricing Officer (TPO) as at Arm's Length Price (ALP) u/s 92CA(3) of the Act. The TPO's role is to ensure pricing is at ALP. Documents were submitted and findings from survey proceedings were available to the TPO. Consistency was maintained as no adjustments were made in prior years. The allocation key should not be disturbed. Regarding depreciation on intangible assets, the Tribunal directed the AO to grant depreciation as per previous rulings in the assessee's favor.....