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of <h1>Income Tax Bill 2025: Clause 170 Requires Secondary Adjustments on Transfer Prices Over One Crore Rupees</h1> Clause 170 of the Income Tax Bill, 2025, mandates secondary adjustments when a primary adjustment of one crore rupees or more is made to a transfer price. This applies if the adjustment is self-made, accepted from an Assessing Officer, determined by an advance pricing agreement, safe harbour rules, or mutual agreement procedures. If excess money from the adjustment isn't repatriated to India, it is deemed an advance to the associated enterprise, with interest computed as prescribed. The assessee may opt to pay an 18% tax on un-repatriated excess money, treated as final payment, with no further deductions allowed. Definitions for terms like 'arm's length price' and 'secondary adjustment' are provided.
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