The concept of secondary adjustments was introduced vide. Finance Act of 2017, by way of insertion of Section 92CE, as yet another initiative to align Indian transfer pricing norms with internationally accepted practices. Recently, CBDT notified new Rule 10CB in the Income tax Rules, 1962 in relation to secondary adjustments which prescribe the time limit for repatriation of excess money and methodology for computation of interest income.
Rakesh Nangia, Managing Partner and Amit Agarwal, Partner with inputs from Anchal Kapoor, Amit Bhalla, and Aakanksha Gupta, Nangia & Co LLP contributed an article on
Secondary adjustments – Analyzing tax, accounting and regulatory implications for Taxsutra.