Arm's length price tolerance: actual transaction price deemed ALP where variation within notified thresholds for wholesale and other cases. 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 relevant assessment year where the variation between the arm's length price and the actual price falls within the notified tolerance ranges. The notification defines wholesale trading by quantitative purchase cost and inventory to sales conditions and applies a narrower tolerance to such transactions, with the memorandum noting retrospective effect and certification of no adverse impact.
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Arm's length price tolerance: actual transaction price deemed ALP where variation within notified thresholds for wholesale and other cases.
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 relevant assessment year where the variation between the arm's length price and the actual price falls within the notified tolerance ranges. The notification defines wholesale trading by quantitative purchase cost and inventory to sales conditions and applies a narrower tolerance to such transactions, with the memorandum noting retrospective effect and certification of no adverse impact.
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