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of <h1>Secondary adjustment required for transfer-pricing primary adjustments unless = Rs 1 crore or AY before 1-4-2016 (Section 92CE)</h1> Where a primary transfer-pricing adjustment increases taxable income or reduces loss-whether made by the taxpayer, accepted by the tax authority, under an advance pricing agreement, safe-harbour, or mutual agreement procedure-the taxpayer must make a corresponding secondary adjustment unless the primary adjustment is = Rs. 1 crore or relates to an assessment year beginning on or before 1-4-2016. Any excess money with an associated enterprise not repatriated within prescribed time is deemed an advance and attracts prescribed interest; alternatively the taxpayer may elect to pay 18% additional tax on that amount, which is final and precludes further secondary adjustment, interest computation, or deductions. Definitions govern associated enterprise, arm's-length price, excess money, and primary/secondary adjustments.
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