9911796707
TMI BlogAmendment of section 92CE.X X X X Extracts X X X X X X X X Extracts X X X X ..... inserted and shall be deemed to have been inserted with effect from the 1st day of April, 2018, namely: Provided further that no refund of taxes paid, if any, by virtue of provisions of this sub-section as they stood immediately before their amendment by the Finance (No.2) Act, 2019 shall be claimed and allowed. ; (b) in sub-section (2), (i) for the words the excess money which , the words the excess money or part thereof, as the case may be, which shall be substituted and shall be deemed to have been substituted with effect from the 1st day of April, 2018; (ii) the following Explanation shall be inserted and shall be deemed to have been inserted with effect from the 1st day of April, 2018, namely: 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 ..... cases. Sub-section ( 1 ) of the said section, inter alia , provides that the assessee shall make secondary adjustment in case where primary adjustment to transfer price takes place as specified therein. The proviso to said sub-section provides exemption in cases where the amount of primary adjustment made in any previous year does not exceed the threshold limit of one crore rupees; and the primary adjustment is made in respect of an assessment year commencing on or before 1st April, 2016. It is proposed to amend clause ( iii ) of the said sub-section so as to provide that the secondary adjustment will be applicable where the primary adjustment to transfer price is determined by an advance pricing agreement entered into by the assessee under ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... art thereof. It is also proposed to insert sub-section (2B) so as to provide that the tax on the excess money or part thereof so paid by the assessee under sub-section (2A) shall be treated as the final payment of tax in respect of the excess money or part thereof not repatriated and no further credit therefor shall be claimed by the assessee or by any other person in respect of the amount of tax so paid. It is also proposed to insert sub-section (2C) so as to provide that 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). It is also propsed to insert sub-section (2D) so as to provide that where the add ..... X X X X Extracts X X X X X X X X Extracts X X X X
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