More than one arm’s-length price is obtained, and the notified tolerance cannot apply. Which method remains outside the dataset range rule even when there are six or more entries, so that the…

Rule 81(6) of the Income-tax Rules, 2026 applies the 35th-65th percentile range only where the most appropriate method is the comparable uncontrolled price, resale price, cost plus or transactional net margin method and the dataset has six or more entries. The profit split method is not listed, so under rule 81(7) the arithmetic mean of the values applies, subject to the notified tolerance.