Part DCA - Safe Harbour Rules for income referred to in clause (i) of sub-section (1) of section 9 chargeable to tax under the head (From Rule 10TI to Rule 10TIC)
Secondary adjustments under transfer pricing require repatriation of excess money within prescribed time limits and interest computation on delayed amounts. Computation of interest income for secondary adjustments under transfer pricing prescribes the time limit for repatriation of excess money within ninety days from specified trigger dates, depending on how the primary adjustment arises. Where excess money is not repatriated within that period, the rule provides for imputed annual interest income at the prescribed benchmark rates for Indian rupee-denominated transactions and foreign currency transactions, and the interest is chargeable from the relevant trigger date. International transaction and exchange conversion are defined for this purpose.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Secondary adjustments under transfer pricing require repatriation of excess money within prescribed time limits and interest computation on delayed amounts.
Computation of interest income for secondary adjustments under transfer pricing prescribes the time limit for repatriation of excess money within ninety days from specified trigger dates, depending on how the primary adjustment arises. Where excess money is not repatriated within that period, the rule provides for imputed annual interest income at the prescribed benchmark rates for Indian rupee-denominated transactions and foreign currency transactions, and the interest is chargeable from the relevant trigger date. International transaction and exchange conversion are defined for this purpose.
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