Rule 10CA - Computation of arm's length price in certain cases

Arm's length price determination: use percentile-based range and median or mean to set transfer pricing outcome.

Where multiple prices arise, construct an ascending dataset of comparables and, where applicable, include weighted averages of comparable uncontrolled transactions from current and prior years using weights tied to the base employed. If the dataset has six or more entries and a non-PM/PS method applies, form an arm's length range from the thirty-fifth to the sixty-fifth percentile; a transaction price within that range is deemed arm's length, otherwise the median of the dataset is the arm's length price. If percentilerules do not apply, use the arithmetic mean subject to a notified de minimis tolerance.