https://www.taxtmi.com/highlights?id=104400 Transfer-pricing tolerance under Rule 10CA(7) can apply where an internal comparable produces a single value, since its arithmetical mean remains that value. Where the variation falls within the notified tolerance, the declared price is treated as arm's length. Corporate-guarantee commission may be determined at 0.5% where identical facts and unchanged circumstances support reliance on an earlier determination. Notional interest on outstanding associated-enterprise receivables depends on verifying a uniform policy of not charging interest to third-party export customers; if substantiated by evidence, no interest adjustment should arise. en-us Thu, 01 Oct 2026 07:40:28 +0530 Thu, 01 Oct 2026 07:40:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=104400 Transfer-pricing tolerance under Rule 10CA(7) can apply where an internal comparable produces a single value, since its arithmetical mean remains that value. Where the variation falls within the notified tolerance, the declared price is treated as arm's length. Corporate-guarantee commission may be determined at 0.5% where identical facts and unchanged circumstances support reliance on an earlier determination. Notional interest on outstanding associated-enterprise receivables depends on verifying a uniform policy of not charging interest to third-party export customers; if substantiated by evidence, no interest adjustment should arise. Highlights Income Tax Thu, 01 Oct 2026 07:40:28 +0530 https://www.taxtmi.com/highlights?id=104400