TP Adjustment - Allocation of Common Cost - we agree with the TPO’s calculation of allocation based on...

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 .....

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