The assessee\u00a0has used allocation key of employee head account. The expenses like rent,\u00a0depreciation, electricity, insurance charges, office maintenance and other\u00a0miscellaneous expenses have no co-relation with the number of employees.\u00a0On the contrary, these expenses have a direct bearing to the revenue\u00a0generation. As per Rule 10-B(1) of the Act, determination of ALP u\/s 92CA(2)\u00a0of the Act, the ALP in relation to an international transaction has to be\u00a0determined by the most appropriate method. In our considered opinion, the\u00a0method adopted by the TPO is slightly better than the method adopted by the\u00a0assessee. More so when the allocation by the assessee is not supported by\u00a0any certificate from the management. Considering the nature of expenses in\u00a0totality, we do not find any merit in the case of the assessee.<\/p>\n","protected":false},"excerpt":{"rendered":"
The assessee\u00a0has used allocation key of employee head account. The expenses like rent,\u00a0depreciation, electricity, insurance charges, office maintenance and other\u00a0miscellaneous expenses have no co-relation with the number of employees.\u00a0On the contrary, these expenses have a direct bearing to the revenue\u00a0generation. …<\/p>\n