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Arm's length price deemed equal to transaction price where variation falls within minimal thresholds for specified trading categories. Notification under the third proviso to section 92C(2), read with rule 10CA proviso, deems the actual transaction price to be the arm's length price for the specified assessment year where the variation between the statutory arm's length price and the transactional price falls within prescribed minimal thresholds for wholesale trading and other cases. 'Wholesale trading' is defined by two objective criteria: purchase cost of finished goods being at least eighty per cent of total trading cost, and average monthly closing inventory being ten per cent or less of sales for the trading activity.
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Provisions expressly mentioned in the judgment/order text.
Arm's length price deemed equal to transaction price where variation falls within minimal thresholds for specified trading categories.
Notification under the third proviso to section 92C(2), read with rule 10CA proviso, deems the actual transaction price to be the arm's length price for the specified assessment year where the variation between the statutory arm's length price and the transactional price falls within prescribed minimal thresholds for wholesale trading and other cases. "Wholesale trading" is defined by two objective criteria: purchase cost of finished goods being at least eighty per cent of total trading cost, and average monthly closing inventory being ten per cent or less of sales for the trading activity.
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