Rule 83 - Time period for repatriation of excess money under section 170(2) and computation of interest income under section 170(4) pursuant to secondary adjustments
Income-Tax Rules, 2026
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Secondary adjustments and repatriation timelines govern excess money, with prescribed interest on unrepatriated amounts under transfer pricing rules. Time limits for repatriation of excess money arising from secondary adjustments are set according to the basis of the primary transfer pricing adjustment, with ninety days generally running from the relevant trigger date. The rule also prescribes imputed annual interest income on unrepatriated excess money, calculated at the applicable State Bank of India lending rate or foreign currency reference rate plus the specified basis-point spread, and charged from the relevant date. For foreign currency transactions, conversion into Indian rupees is made using the telegraphic transfer buying rate on the last day of the tax year.
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 and repatriation timelines govern excess money, with prescribed interest on unrepatriated amounts under transfer pricing rules.
Time limits for repatriation of excess money arising from secondary adjustments are set according to the basis of the primary transfer pricing adjustment, with ninety days generally running from the relevant trigger date. The rule also prescribes imputed annual interest income on unrepatriated excess money, calculated at the applicable State Bank of India lending rate or foreign currency reference rate plus the specified basis-point spread, and charged from the relevant date. For foreign currency transactions, conversion into Indian rupees is made using the telegraphic transfer buying rate on the last day of the tax year.
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