9911796707
TMI BlogSecondary adjustment in certain cases.X X X X Extracts X X X X X X X X Extracts X X X X ..... etermined by an advance pricing agreement entered into by the assessee under 2[section 92CC, on or after the 1st day of April, 2017,]; (iv) is made as per the safe harbour rules framed under section 92CB; or 30 (v) is arising as a result of resolution of an assessment by way of the mutual agreement procedure under an agreement entered into under section 90 or section 90A for avoidance of doubl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hich] is available with its associated enterprise, if not repatriated to India within the time as may be prescribed, shall be deemed to be an advance made by the assessee to such associated enterprise and the interest on such advance, shall be computed in such manner as may be prescribed. 6[Explanation.--For the removal of doubts, it is hereby clarified that the excess money or part thereof may b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... shall be allowed to the assessee in respect of the amount on which tax has been paid in accordance with the provisions of sub-section (2A). (2D) Where the additional income-tax referred to in sub-section (2A) is paid by the assessee, he shall not be required to make secondary adjustment under sub-section (1) and compute interest under sub-section (2) from the date of payment of such tax.] (3) F ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... erprise to reflect that the actual allocation of profits between the assessee and its associated enterprise are consistent with the transfer price determined as a result of primary adjustment, thereby removing the imbalance between cash account and actual profit of the assessee.] ********** Notes:- 1. Inserted vide THE FINANCE ACT, 2017 w.e.f. 1st day of April, 2018 2. Substituted vide FINANCE ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
