Contours of Transfer Pricing Other Method VII of VII

Rule 10AB institutionalises flexibility within the arm’s length framework by permitting the use of “any method” that reliably approximates the price between independent enterprises. 

It applies where none of the prescribed methods are appropriate, or where an alternative method provides a more reliable measure of the arm’s length price. 

Particularly relevant for intangibles, financial instruments, and restructurings, the method is analytically robust but model-driven—making assumption integrity, data credibility, and documentation central to defensibility.