Test an international related-party transaction against a comparable set. Builds the arm's-length range using the Indian Rule 10CA method (35th–65th percentile for six or more comparables) and computes any adjustment to the median.
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Inputs
Operating cost or revenue, to size any TP adjustment.
Result
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Arm's length range
Computational aid only. Implements the Rule 10CA range (35th–65th percentile) for datasets of six or more comparables; smaller sets fall back to the arithmetic mean with a tolerance band. It does not perform comparable searching, accept/reject screening, or working-capital/risk adjustments, which require a database and professional judgement. Confirm the method, PLI and comparables against the TP documentation requirements.