Flora of Bhutan gives the following keys:
8. Wide or narrow, pale, scarious, lacerate appendage on margins of outer and middle phyllaries near base of spine . ...
C. wallichii (specimen at
POWO)
+ Phyllaries uniformly tapered, margin sometimes denticulate but not scarious- dilated near the base of the spine . . . .. 9
9. Leaves moderately spiny (spines 5mm); phyllaries purplish, outer usually ending in spine 2--4mm . .. ..
C. tibeticum (syn. of
Cirsium argyracanthum DC. as per
POWO) (specimen at
POWO)
+ Leaves very spiny (spines 5-12mm); phyllaries greenish, outer with spines 4-8mm . . . ..
C. verutum (specimen at
POWO)
In view, it should be
C. wallichii (specimen at
POWO).