Secondary adjustment under transfer pricing applies even when taxpayer avails dispute-resolution scheme, subject to limited historical exception.

Secondary adjustment continues to apply to transfer-pricing primary adjustments even when the taxpayer avails the Vivad se Vishwas dispute-resolution scheme; the mechanism for recalibrating deemed inter-company loans or deemed adjustments remains operative. A limited primary adjustment exception excludes primary adjustments that relate to tax assessment years commencing on or before the specified historical cutoff, so those earlier-year primary adjustments are not subject to the secondary adjustment mechanism.

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