Arms length price us 92C variation in wholesale trading up to 1% and 3 % in other cases to be deemed ALP for AY 2022-23
MINISTRY OF FINANCE
(Department of Revenue)
New Delhi, the 28th June, 2022
[INCOME-TAX]
S.O. 2928(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 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 one per cent. of the latter in respect of wholesale trading and 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 assessment year 2022-2023.
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 per cent. or more of the total cost pertaining to such trading activities; and(ii) average monthly closing inventory of such goods is ten per cent. or less of sales pertaining to such trading activities.
[F. No. 500/1/2014-APA-II]
RUCHIKA SHARMA, Under Secy.
Explanatory Memorandum
The notification provides for tolerance range of one per cent. for wholesale trading and three per cent. in all other cases for assessment year 2022-2023. It is certified that none will be adversely affected by the retrospective effect being given to the notification.
No additional evidence to be admitted by CIT(A) unless Assessing Officer is given opportunity of examining the evidence and rebut…
ICAI notifies dates for CA Foundation & Intermediate Examination September 2024. The Council of the Institute of Chartered Accountants of…
ABCAUS Excel Depreciation Calculator FY 2023-24 under Companies Act 2013 as per Schedule-II Version 05.18 The maiden ABCAUS Excel Companies…
Reply was not submitted as e-filing portal was closed, Assessment order set aside as time given for submitting reply was…
E-way bill expired due to vehicle break down only a technical breach and non extension of its time period cannot…
No rejection of GST appeal for mere non filing of certified copy of the decision as per rule 108 of…