State with brief reasons, which method of determination of Arm's Length Price (ALP) will be most appropriate in the following cases: (a) AY Ltd., Bengaluru provided identical call centre services to both related and unre

AY Ltd., Bengaluru provided identical call centre services to both related and unrelated parties. In respect of provision of services, the most appropriate method can be the Comparable Uncontrolled Price (CUP) method. Further, Cost Plus Method (CPM) and Transactional Net Margin method (TNMM) can also be considered, since in all these three methods there are similar transactions with related parties and unrelated parties; and adjustments are made for functional differences.