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)
Interest on secondary adjustments must be computed using prescribed market reference rates when excess funds are not repatriated. Imputed interest on unrepatriated excess money pursuant to secondary adjustments under section 92CE is triggered where repatriation does not occur within ninety days counted from specific dates tied to the nature of the primary adjustment (suo motu return adjustment, AO/appellate order, advance pricing agreement timings, safe harbour option, or MAP resolution). Interest is computed with reference to prescribed domestic and international benchmark rates plus specified margins, and becomes chargeable from the applicable triggering date for each category. International transactions and the exchange rate methodology are defined for conversion purposes.
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Provisions expressly mentioned in the judgment/order text.
Interest on secondary adjustments must be computed using prescribed market reference rates when excess funds are not repatriated.
Imputed interest on unrepatriated excess money pursuant to secondary adjustments under section 92CE is triggered where repatriation does not occur within ninety days counted from specific dates tied to the nature of the primary adjustment (suo motu return adjustment, AO/appellate order, advance pricing agreement timings, safe harbour option, or MAP resolution). Interest is computed with reference to prescribed domestic and international benchmark rates plus specified margins, and becomes chargeable from the applicable triggering date for each category. International transactions and the exchange rate methodology are defined for conversion purposes.
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