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 ..... ee; (iii) is determined 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he excess money or part thereof, as the case may be, which ] 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t of tax so paid. (2C) No deduction under any other provision of this Act 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 comput ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ent means an adjustment in the books of account of the assessee and its associated enterprise 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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