Transfer-pricing tolerance band applies to a single-value internal comparable, treating the declared price as arm's length.

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....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.....