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Tolerance Range Under Transfer Pricing

Notification No. 116, dated 18-10-2024

The Central Board of Direct Taxes (CBDT) has notified that the tolerance limit of 1 percent for wholesale trading and 3 percent in all other cases for ALP determination during the Assessment Year 2024-25. The same tolerance limit was notified by the board for the Assessment Year 2023-24.

“Wholesale trading” means an international transaction or specified domestic transaction of trading in goods, which fulfils the following conditions:

  • The purchase cost of finished goods is 8% or more of the total cost pertaining to such trading activities; and
  • The average monthly closing inventory of such goods is 10% or less of sales pertaining to such trading activities.
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