Case law › Notifications › 2025 › Notification No. 157/2025 [F. No. 500/1/2014-APA-II] / SO 5053(E)

Notification 6 November 2025

Notification No. 157/2025 [F. No. 500/1/2014-APA-II] / SO 5053(E)

Ministry of Finance

What this is

Notification No. 157/2025 [F. No. 500/1/2014-APA-II] / SO 5053(E) was published on 6 November 2025. Its subject is Ministry of Finance.

This notifies a named person, body, fund or instrument for the purpose of a provision. Nothing in it changes the provision itself.

The provisions it speaks to

Left, the provision of the Income-tax Act, 1961 as the instrument itself names it. Right, the section of the Income-tax Act, 2025 that the department’s own concordance maps it to — which is where the same ground is now covered.

Under the 1961 Act	Now
s.92C	s.165

The instrument, as the Board published it

The department publishes this one only as a PDF, so the words below were read out of that PDF by machine. That reading can carry its own mistakes — a misread number, a broken line. Check the signed document before you rely on a figure in it.

MINISTRY OF FINANCE
(Department of Revenue)
NOTIFICATION
New Delhi, the 6th November, 2025
Income Tax
S.O. 5053(E).— In exercise of the powers conferred by the third proviso to sub-section (2) of section 92C of the Income-tax Act, 1961 (43 of 1961)(hereafter referred to as the said Act) read with the proviso to sub-rule (7) of rule 10CA of the Income-tax Rules, 1962, the Central Government hereby notifies that where the variation between the arm's length price determined under section 92C of the said Act and the price at which the international transaction or specified domestic transaction has actually been undertaken does not exceed, (i) one per cent. of the latter in respect of wholesale trading; and (ii) three per cent. 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 the assessment year 2025-2026.

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:-
a. purchase cost of finished goods is eighty per cent. or more of the total cost pertaining to such trading activities; and
b. average monthly closing inventory of such goods is ten per cent. or less of sales pertaining to such trading activities.

[No.157/2025/F. No. 500/1/2014-APA-II]
KARTHIK CHEBOLI, Deputy Commissioner of Income Tax (OSD)(APA-I)FT&TR -I, CBDT

Explanatory Memorandum
The notification provides for tolerance range of one per cent. for wholesale trading and three per cent. in all other cases for the assessment year 2025-2026. It is certified that none will be adversely affected by the retrospective effect being given to the notification.

Uploaded by Dte. of Printing at Government of India Press, Ring Road, Mayapuri, New Delhi-110064
and Published by the Controller of Publications, Delhi-110054.

What it names

Rules it names. Rule 10CA of the Income-tax Rules, 1962. The 1962 Rules were replaced by the Income-tax Rules, 2026, which renumbered nearly everything: a rule number quoted here almost never means the same rule today.

On the same provision

Other instruments in this library that name the same provision of the 1961 Act. They are not necessarily still operative, and a later one may have replaced an earlier one without saying so.

Notification No. 116/2024 [F. No. 500/1/2014-APA-II] / SO 4571(E) — Ministry of Finance 18 October 2024
Notification No. 46/2023 [F. No. 500/1/2014-APA-II] / SO 2777(E) — Ministry of Finance 26 June 2023
Notification No. 70/2022 [F. No. 500/1/2014-APA-II] / SO 2928(E) — Ministry of Finance 28 June 2022
Notification No. 124/2021 [F. No. 500/1/2014-APA-II] / S.O. 4586(E) — Ministry of Finance 29 October 2021
Notification No. 83/2020 [F.No.500/1/2014-APA-II] / SO 3660(E) — रुजचका िमा, अिर सजचि 19 October 2020
Notification No. 64/2019 [F.No. 500/1/2014-APA-II] / SO 3272(E) — Ministry of Finance 13 September 2019

What a notification is. A notification is made under a power the Act itself gives, and within that power it is law — unlike a circular, which only binds the department. Its reach is the reach of the enabling provision and no wider, and the date it carries decides from when it works.

Source: the Income Tax Department’s own published text — its page for this instrument.