https://www.taxtmi.com/caselaws?id=799204 Rule 10CA(7) requires the arm's length price to be determined by the arithmetical mean where the prescribed comparable-based method applies. The notified tolerance is one per cent only for qualifying wholesale trading in goods and three per cent for all other transactions. Sub-licensing constitutes a service rather than wholesale trading in goods, particularly where the required inventory-related conditions are not met. Consequently, where the variation between the actual transaction price and the arithmetical mean falls within the applicable three per cent range, the actual price is deemed to be the arm's length price and no transfer-pricing adjustment is warranted. en-us Fri, 10 Jul 2026 00:00:00 +0530 Fri, 18 Sep 2026 07:32:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799204 Rule 10CA(7) requires the arm's length price to be determined by the arithmetical mean where the prescribed comparable-based method applies. The notified tolerance is one per cent only for qualifying wholesale trading in goods and three per cent for all other transactions. Sub-licensing constitutes a service rather than wholesale trading in goods, particularly where the required inventory-related conditions are not met. Consequently, where the variation between the actual transaction price and the arithmetical mean falls within the applicable three per cent range, the actual price is deemed to be the arm's length price and no transfer-pricing adjustment is warranted. Case-Laws Income Tax Fri, 10 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799204