Arm's length price under the other method depends on comparable uncontrolled transactions and relevant market circumstances.

The other method for determination of arm's length price applies to an international transaction or a specified domestic transaction by reference to a price charged or paid, or that would have been charged or paid, for the same or similar uncontrolled transaction between non-associated enterprises under similar circumstances. The method is fact-sensitive and relies on comparable market pricing, considering all relevant facts.

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