Transfer Pricing: Head Count method for allocation of common expenses needs to be applied

Fujitsu India Pvt. Ltd. Vs DCIT (Delhi High Court) Delhi High Court has partially allowed an appeal by Fujitsu India Pvt. Ltd. against an Income Tax Appellate Tribunal (ITAT) order concerning a transfer pricing adjustment for  Assessment Year 2008-09. The case primarily involved two questions of law: the suitability of using a “headcount” method for allocating common expenses and the validity of including certain companies as comparables. The initial assessment by the Assessing Officer (AO), based on the Transfer Pricing Officer’s (TPO) benchmarking, had resulted in a transf...