Income Tax Notification 157/2025 Dated 06/11/2025 – Arm’s Length Price (ALP) Tolerance Range for AY 2025-26 

The Central Government has set a tolerance range for the variation between the calculated ALP and the actual transaction price for international or specified domestic transactions. If the variation does not exceed one percent of the actual price for wholesale trading, or three percent in all other cases, the actual transaction price will be deemed to be the ALP.. “Wholesale trading” is explicitly defined as trading in goods where the purchase cost of finished goods constitutes eighty percent or more of the total trading cost, and average monthly closing inventory is ten percent or less of the sales related to trading activity. 

(Link: Income Tax Notification 157/2025 Dated 06/11/2025)

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