Govt. Notifies New Tolerance Range for Arm’s Length Price: 1% for Wholesale Trading, 3% for Others:

The Finance Ministry has notified new transfer pricing tolerance limits of 1% for wholesale trading and 3% for other transactions for FY 2025-26.
MoF Revises Acceptable Margin For Arm’s Length Pricing Under Section 92C

Govt. Notifies New Tolerance Range for Arm’s Length Price: 1% for Wholesale Trading, 3% for Others
The Ministry of Finance (Department of Revenue) has recently issued an official notification [No.157/2025/F. No. 500/1/2014-APA-II], dated November 06, 2025, regarding transfer pricing (that is, pricing between related international or domestic transactions).
Through the present notification, the Central Government of India has served conditions under which an actual international transaction or specified domestic transaction will be accepted as the arm’s length price (ALP)
The notification says that for the financial year 2025-26 (assessment year 2026-27), if the difference between the arm’s length price (ALP) determined under section 92C of the said Act and the price at which the international transaction or specified domestic transaction occurs does not exceed 1% of wholesale trading, or 3% for all other types of transactions, then the actual transaction price will be accepted as the arm’s length price.
The Ministry of Finance has issued this notification in exercise of its powers granted under subsection (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.
For this notification, “wholesale trading” means an international or domestic transaction involving the buying and selling of goods that fulfils both of the following conditions:
- The purchasing cost of finished goods is 80% or more of the total cost belonging to such trading activities, and
- The average monthly closing inventory of such goods is 10% or less of sales belonging to such trading activities.
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Saloni Kumari
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Saloni is a Content Writer with 2+ years of experience at studycafe.in. She writes legal, taxation, and finance related content including GST, Income Tax etc. Skilled in translating complex judicial pronouncements and regulatory developments into clear, and reader-friendly articles. Experienced in covering judgements of ITAT, High Court, GSTAT, and news related to Income Tax, GST, and corporate law. She can be reached at [email protected].
Saloni is a Content Writer with 2+ years of experience at studycafe.in. She writes legal, taxation, and finance related content including GST, Income Tax etc. Skilled in translating complex judicial pronouncements and regulatory developments into clear, and reader-friendly articles. Experienced in covering judgements of ITAT, High Court, GSTAT, and news related to Income Tax, GST, and corporate law. She can be reached at [email protected].
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