On 13 September 2019, the Central Board of Direct Taxes (CBDT) published Notification No. 64/2019, which sets a tolerance range for the variation between the arm’s length price and the transaction price for the 2019-20 assessment year. The CBDT also confirmed that that the prevailing 1% tolerance range for wholesale trading and the 3% range for all other international transactions and for certain domestic transactions will be maintained.

This range applies to all transactions that were made in the fiscal year ended 31 March 2019. The CBDT also confirmed that the retrospective effect of the notification has no adverse effects.