Clarification with regard to provisions of secondary adjustment and giving an option to assessee to make one-time payment

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..... international best practices, section 92CE of the Act provides for secondary adjustments in certain cases. It, inter alia, provides that the assessee shall be required to carry out secondary adjustment where the primary adjustment to transfer price, has been made suo motu, or made by the Assessing Officer and accepted by him; or is determined by an advance pricing agreement entered into by him .....

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..... posed to amend section 92CE of the Act so as to provide that:- (i) the condition of threshold of one crore rupees and of the primary adjustment made upto assessment year 2016-17 are alternate conditions; (ii) the assessee shall be required to calculate interest on the excess money or part thereof; (iii) the provision of this section shall apply to the agreements which have been signed on or .....

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..... aid; (vii) the deduction in respect of the amount on which such tax has been paid , shall not be allowed under any other provision of this Act; and (viii) if the assessee pays the additional income-tax, he will not be required to make secondary adjustment or compute interest from the date of payment of such tax. The amendments proposed in para (i) to (iv) above will take effect retrospectivel .....

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