Arm's length price: small permitted variation lets actual transaction price be treated as arm's length for notified assessment periods. Notification deems the actual transaction price to be the arm's length price for notified assessment periods where the variation between the arm's length price determined under the transfer pricing provisions and the actual price falls within prescribed small thresholds; a distinct, tighter threshold applies to wholesale trading, which is defined by high purchase-cost dominance in total cost and low average monthly closing inventory relative to sales.
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Provisions expressly mentioned in the judgment/order text.
Arm's length price: small permitted variation lets actual transaction price be treated as arm's length for notified assessment periods.
Notification deems the actual transaction price to be the arm's length price for notified assessment periods where the variation between the arm's length price determined under the transfer pricing provisions and the actual price falls within prescribed small thresholds; a distinct, tighter threshold applies to wholesale trading, which is defined by high purchase-cost dominance in total cost and low average monthly closing inventory relative to sales.
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