Government Notify the Permissible Variation for determination of Arm’s Length Price for AY 2025–26 under section 92C of Income-tax Act, 1961 - 157/2025 - Income Tax

Arm's length price tolerance set; actual transaction price deemed arm's length when variation falls within notified tolerances.

Notification prescribes a tolerance band for determining arm's length price under section 92C, deeming the actual transaction price to be the arm's length price where variation between the statutory arm's length price and the actual price falls within prescribed tolerances. It distinguishes wholesale trading by objective criteria-high purchase cost share of finished goods and low average monthly closing inventory relative to sales-and applies a narrower tolerance to such trading while applying a wider tolerance to other transactions, thereby limiting transfer pricing adjustments within the notified band.