MINISTRY OF FINANCE
(Department of Revenue)
NOTIFICATION
New Delhi, the 18th October, 2024
INCOME-TAX
S.O. 4571(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 2024-2025
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.
[Notification No. 116/2024/F. No. 500/1/2014-APA-II]
KARTHIK CHEBOLI, Dy. Commissioner of Income Tax (OSD)(APA-I)
FT&TR -I, CBDT