Section 92C of the Income-tax Act, 1961 - Transfer Pricing - Computation of arm’s length price - Notified tolerable limit for determination of ALP
Notification No. 45/2014 [F.No.500/1/2014-APA-II] SO 2478(E) was published on 23 September 2014. Its subject is Section 92C of the Income-tax Act, 1961 - Transfer Pricing - Computation of arm’s length price - Notified tolerable limit for determination of ALP.
This is not the department’s typed text. The department published this one as a scanned image of a signed paper, so there is no text in the file to copy. What follows was read off that image by optical character recognition and is reproduced without correction — the mistakes you can see are the machine’s, and there may be others you cannot. It is here so the document can be found and read; it is not a substitute for the file, which is linked below. Do not quote from this page.
9g! _| ‘THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)]
MINISTRY OF FINANCE _
. a (Department of Revenue)
| 7 NOTIFICATION _ | -
. New Delhi, the 23rd September, 2014
[INCOME TAX] _ .
. §.O. 2478(E).—In exercise of the powers conferred by the second proviso to sub-section (2) of section 92C of the Income-tax Act, 1961 (43 of 1961), the Central Government hereby notifies that where the variation between the arm’s length price determined under section 92C and the price at which the international transaction or specified 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:-
(i) purchase cost of finished goods is eighty percent or more of the total cost pertaining to such :
, trading activities; and
; (ii) average monthly closing inventory of such goods is ten percent or less of sales pertaining to such
. trading activities. mo
[Notification No. 45/2014/F. No. 500/1/2014-APA-II]
| _ _ GAURAV SHARMA, Under Secy.
, _ Printed by the Manager, Government of India Press, Ring Road, Mayapuri, New Delhi-110064
and Published by the Controller of Publications, Delhi-110054.
Source: the department’s scanned file.
← Notification No. 47/2014 [F. No. 501/08/1979-FTD-I] / SO 2488(E) · Notification No. 44/2014 [F.No. 501/3/99-FTD-II] / SO 2465(E) →
Source: the Income Tax Department’s own published text — its page for this instrument.