Transfer Pricing Adjustments: Rule 10B(4) Clarifies Comparable Transaction Selection, Allows Prior Data Consideration for Analysis.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....TP adjustment - comparable selection - Rule 10B(4)- the data to be used in analysing the comparability of an uncontrolled transaction shall be the data relating to the financial year - proviso to this rule further provides that data relating to a period not being more than two years prior to [the current year] may also be considered if such data have an influence on the determination of TP in relation to the transactions being compared....