Dependent Agent PE unresolved for lack of factual inquiry; arm's-length distribution accepted; royalty claim rejected; 15% refund interest (Section 24...
Exemption under s.10(23C)(iiiad) upheld; appeal allowed, interest and dividends excluded from annual receipts, disallowance deleted, capital gains exe...
The government notifies that for assessment year 2025-26 an international or specified domestic transaction's actual price will be deemed the arm's-length price if the difference between the arm's-length price under section 92C and the actual transaction price does not exceed 1% of the actual price for wholesale trading and 3% for all other cases. Wholesale trading is defined by (a) finished goods purchase cost ≥80% of total trading costs and (b) average monthly closing inventory ≤10% of related sales. The explanatory memorandum states the tolerance ranges and that no one will be adversely affected by retrospective application.
The government notifies that for assessment year 2025-26 an international or specified domestic transaction's actual price will be deemed the arm's-length price if the difference between the arm's-length price under section 92C and the actual transaction price does not exceed 1% of the actual price for wholesale trading and 3% for all other cases. Wholesale trading is defined by (a) finished goods purchase cost ≥80% of total trading costs and (b) average monthly closing inventory ≤10% of related sales. The explanatory memorandum states the tolerance ranges and that no one will be adversely affected by retrospective application.
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