Secondary adjustment requires deemed advances and interest where transfer pricing primary adjustments leave excess funds abroad unless repatriated.

Section 92CE mandates a secondary adjustment where a primary adjustment to transfer price increases the taxpayer's income or reduces its loss. If the resulting excess money remains with the associated enterprise and is not repatriated within the prescribed time, it is deemed to be an advance by the taxpayer to that associated enterprise and interest on the deemed advance is computed as prescribed. The section applies where primary adjustments arise from specified mechanisms and includes a monetary de minimis exemption and definitions of associated enterprise, arm's length price, excess money, primary adjustment, and secondary adjustment.

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