Benefit of tolerance limit of +/- 5% as contained in Section 92C(2) available even when one comparable remains in comparable set [Sec 92C of ITA'61

Benefit of tolerance limit of +/- 5% as contained in Section 92C(2) available even when one comparable remains in comparable set [Sec 92C of ITA'61 - Sec 165 of ITA'25] https://www.taxtmi.com/article/detailed?id=17097 Transfer pricing tolerance range under the second proviso to section 92C(2) deems the actual transaction price to be the arm's length price where its variation from the determined arm's length price is within the notified limit. The expression "so determined" covers an arm's length price determined under both the main provision and the first proviso. The tolerance benefit therefore applies whether the arm's length price arises from multiple comparable prices or from a single remaining comparable in the comparable set. en-us Tue, 04 Aug 2026 08:40:30 +0530 Tue, 04 Aug 2026 08:40:30 +0530 TaxTMI RSS Generator Benefit of tolerance limit of +/- 5% as contained in Section 92C(2) available even when one comparable remains in comparable set [Sec 92C of ITA'61 - Sec 165 of ITA'25] https://www.taxtmi.com/article/detailed?id=17097 Transfer pricing tolerance range under the second proviso to section 92C(2) deems the actual transaction price to be the arm's length price where its variation from the determined arm's length price is within the notified limit. The expression "so determined" covers an arm's length price determined under both the main provision and the first proviso. The tolerance benefit therefore applies whether the arm's length price arises from multiple comparable prices or from a single remaining comparable in the comparable set. Articles Income Tax Tue, 04 Aug 2026 08:40:30 +0530 https://www.taxtmi.com/article/detailed?id=17097