When can uncontrolled transactions be said comparable to international transactions? Which data can be used for the comparability of an uncontrolled transaction with an international transaction? Furnish your answer in t

CUP method under transfer pricing: As per rule 10B(3) of the Income Tax Rules, 1962, an uncontrolled transaction shall be comparable to an international transaction if: none of the differences, if any, between the transactions being compared, or between the enterprises entering into such transactions are likely to materially affect the price or cost charged or paid in, or the profit arising from, such transactions in the open market; or reasonably accurate adjustments can be made to eliminate the material effects of such differences. If the differences are material and the adjustments cannot be made, the transaction cannot be taken as comparable transaction, then such transaction shall be ignored. The internal comparable (i.e. transactions entered into by the associated enterprise with unrelated party) as far as possible should be selected as these will provide mode reliable and accurate data as compared to external comparable data i.e. transaction with third parties. As per Rule 10B(5) of the Income Tax Rules, 1962, In a case where the most appropriate method for determination of the arm's length price of an international transaction entered into on or after 1/4/14, is the method specified in clause (b), clause (c) or clause (e) of sub-section (1) of section 92C, then, notwithstanding anything contained in sub-rule (4), the data to be used for analysing the comparability of an uncontrolled transaction with an international transaction shall be: the data relating to the current year; or the data relating to the financial year immediately preceding the current, if the data relating to the current year is not available at the time of furnishing the return of income by the assessee, for the assessment year relevant to the current year: Provided that where the data relating to the current year is subsequently available at the time of determination of arm's length price of an international transaction during the course of any assessment proceeding for the assessment year relevant to the current year, then, such data shall be used for such determination irrespective of the fact that the data was not available at the time of furnishing the return of income of the relevant assessment year.