Discuss the factors to be considered by the Assessing Officer while selecting the appropriate transfer pricing method.

Factors to be considered by the Assessing Officer while selecting an appropriate transfer pricing method are as under: The nature and class of the International or Specified Domestic Transaction. The class or classes of Associated Enterprises entering into the transactions and the functions performed by them taking into account assets employed or to be employed and risk assumed by each enterprises. The availability, coverage and reliability of data necessary for application of the method. The degree of comparability existing between the International transaction or Specified Domestic Transaction and the uncontrolled transaction, and between the enterprises entering into such transaction. The extent to which reliable and accurate adjustments can be made to account for differences, if any, between the International or Specified Domestic Transaction and the comparable uncontrolled transactions or between the enterprises entering into such transactions. The nature, extent and reliability of assumptions required to be made in the application of the method.