CBDT Notifies 1% and 3% Arm's Length Price Tolerance for AY 2025-26



Quick Summary
The Central Board of Direct Taxes (CBDT) has announced new guidelines for transfer pricing for the Assessment Year 2025-26. A 1% tolerance range will apply to wholesale trading transactions, while a 3% range will be used for all other international or specified domestic transactions. If the actual transaction price falls within these limits, it will be considered the arm's length price, simplifying compliance for businesses.

The Ministry of Finance, Department of Revenue, has issued Notification No. S.O. 5053(E) dated November 6, 2025, specifying the tolerance range for determining the arm's length price (ALP) under Section 92C of the Income-tax Act, 1961, for the Assessment Year 2025-26. As per the notification, the C
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1 Year PLAN
1999
(Excl. of GST ₹359)

BEST VALUE
2 Years PLAN
3499
(Excl. of GST ₹629)

3 Months PLAN
999
(Excl. of GST ₹179)

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FAQ :

For wholesale trading, the arm's length price tolerance is 1% for AY 2025-26.

For all other international or specified domestic transactions, the arm's length price tolerance is 3% for AY 2025-26.

The actual transaction price will be deemed the arm's length price if the variation remains within the specified 1% or 3% limits.

Wholesale trading is defined as transactions where the purchase cost of finished goods is 80% or more of the total trading cost, and the average monthly closing inventory is 10% or less of sales.

No, the CBDT has stated that the retrospective application of this notification will not adversely affect any taxpayer.

Attached File : 671907_25759_267425.pdf



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Finance news reporter covering taxation, GST, income tax, business compliance, and economy updates. I simplify complex financial topics into easy-to-understand articles for professionals, taxpayers, and business owners on leading finance and tax platforms.

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