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          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.

          Provisions expressly mentioned in the judgment/order text.

          <h1>Most appropriate method: choose the transfer pricing method best suited to transaction facts to ensure reliable arm's length pricing.</h1> The Most Appropriate Method is the method best suited to the facts and circumstances of each particular international or specified domestic transaction and which provides the most reliable measure of an arm's length price. Selection must consider: the nature and class of the transaction; the classes and functions of associated enterprises including assets and risks; availability, coverage and reliability of necessary data; degree of comparability with uncontrolled transactions and enterprises; extent of reliable adjustments; and the nature and reliability of required assumptions.

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