If the taxpayer avails Vivad se Vishwas for Transfer Pricing adjustment, will provisions of section 92CE of the Act apply separately?

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.