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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 party to the controlled transactions.
(c) Availability of Most reliable data of tested party and requirement of minimum adjustments is also one of the most important aspects in selection of tested party.