When can uncontrolled transactions be taken as comparable to international transactions? Which data can be used for the comparability of an uncontrolled transaction with an international transaction?

As per rule 10B(3) , uncontrolled transaction can be taken as comparable to international transaction only 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 difference. 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. Further, as far as possible the internal comparable (i.e. transactions entered into by the associated enterprise with unrelated party) should be selected as these will provide more reliable and accurate data as compared to external comparable data i.e. (transaction with third parties). As per rule 10B(4) , the data to be used in analyzing the comparability of an uncontrolled transaction with an international transaction shall be the data relating to the financial year in which the international transaction has been entered into. However, data relating to a period not being more than 2 years prior to such financial year may also be considered if such data reveals facts which could have an influence on the determination of transfer prices in relation to the transactions being compared.