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25. From the above guidance certain principles emerges in selection of tested party
(a) The choice available of tested party for comparability only in CUP method , TNMM and ‗Other method', in other methods such as RPM and CPM choice of selecting a tested party is not available. In any case,it is not required in Profit split method.
(b) The tested party normally should be the least complex partytothe controlled transactions.