On 23 September 2014, India's Ministry of Finance issued Notification No. 45/2014/F No. 500/1/2014-APA-II, which states that for year of assessment 2014-2015, when an international transaction does not vary from the arm's length price determined under ITA section 92C by more than 1% in the case of wholesale trading and 3% in other cases, such transactions will be deemed to be at the arm's length price.
International transactions will be considered wholesale trading for the purpose of the not…