Variation between the arms length price determined under section 92C of the said Act and the price at which the international transaction of specified domestic transaction has actually been undertaken does not exceed one per cent.

4031 GI/202 3 (1) EXTRAORDINARY PART II —Section 3 —Sub-section ( ii) PUBLISHED BY AUTHORITY No. 2657] NEW DELHI, MONDAY , JUNE 26, 2023/ASHADHA 5, 194 5 CG-DL-E-26062023-246821 MINISTRY OF FINANCE (Department of Revenue) NOTIF ICATION New Delhi, the 26 th June, 2023 INCOME -TAX S.O. 2777 (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 Ce ntral 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 n ot 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 b e the arm’s length price for assessment year 2023 -2024. 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 condition s, 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 act ivities. [Notification No. 46/2023/F. No. 500/1/2014 -APA -II] Dr. VIJIT PATEL , 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 yea r 2023 -2024. 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 R oad, Mayapuri, New Delhi -110064 and Published by the Co ntroller of Publications, Delhi -110054.