Secondary adjustment aligns accounting between related parties with transfer pricing primary adjustment to remove cash profit imbalance. Secondary Adjustment requires amendment of the assessee's and its associated enterprise's books of account to align actual profit allocation with the transfer price determined by a primary adjustment, thereby removing the divergence between cash accounts and the assessee's reported profit.
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Provisions expressly mentioned in the judgment/order text.
Secondary adjustment aligns accounting between related parties with transfer pricing primary adjustment to remove cash profit imbalance.
Secondary Adjustment requires amendment of the assessee's and its associated enterprise's books of account to align actual profit allocation with the transfer price determined by a primary adjustment, thereby removing the divergence between cash accounts and the assessee's reported profit.
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