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TMI BlogClarification with regard to provisions of secondary adjustment and giving an option to assessee to make one-time paymentX X X X Extracts X X X X X X X X Extracts X X X X ..... ansfer pricing provisions with 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s and to make the secondary adjustment regime more effective and easy to comply with, it is proposed 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o be increased by a surcharge of twelve per cent; (vi) the tax so paid shall be the final payment of tax and no credit shall be allowed in respect of the amount of tax so paid; (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 t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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