The Income Tax Department has come out with rules for operationalising the provisions of secondary adjustment in books of accounts to reflect actual allocation of profits between a company and its arm. According to an official release,It prescribes the time limit for repatriation of excess money and the rate of interest to be applied for computing the income in case of failure to repatriate the excess money within the prescribed time limit. The time-limit of 90 days for repatriation of excess money shall begin only when the primary adjustments exceeding one crore rupees made in respect of Assessment Year 2017-18 or later, attains finality. It said, in case the transfer pricing order is appealed against by the taxpayer, the time limit for repatriation will commence only after the appeal is finalised by the appellate authority.
News On AIR | June 19, 2017 9:39 PM
CBDT notifies secondary adjustment rule in transfer pricing