CBDT has issued a notification under Section 92C of the Income-Tax Act, 1961 for Transfer Pricing and Computation of Arm’s Length Price to keeps Tolerable Limit for ALP unchaged for Assessment Year 2014-15.
CBDT hereby notifies that where the variation between the arm’s length price determined under section 92C and the price of which the international transaction or pecified domestic transaction has actually been undertaken does not exceed one percent of the latter in respect of wholesale trading and three percent of the latter. In all other cases, the price at which the international transaction or specified domestic transaction has actually been undertaken shall be deemed to be the arm’s length price for assessment year 2014-15.
Explanation :
For the purposes of this notification, “wholesale trading” means an international transaction or specified domestic transaction of trading in goods, which fulfils the following conditions, namely :—
CBDT hereby notifies that where the variation between the arm’s length price determined under section 92C and the price of which the international transaction or pecified domestic transaction has actually been undertaken does not exceed one percent of the latter in respect of wholesale trading and three percent of the latter. In all other cases, the price at which the international transaction or specified domestic transaction has actually been undertaken shall be deemed to be the arm’s length price for assessment year 2014-15.
Explanation :
For the purposes of this notification, “wholesale trading” means an international transaction or specified domestic transaction of trading in goods, which fulfils the following conditions, namely :—
- purchase cost of finished goods is eighty percent or more of the total cost pertaining to such trading activities; and
- average monthly closing inventory of such goods is ten percent or less of sales pertaining to such trading activities.
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