Secondary adjustment interest computation requires repatriation deadline; failure triggers imputed interest based on currency-specific benchmarks. Secondary adjustments under section 92CE require repatriation of excess funds within a uniform ninety-day period from specified triggering events tied to primary transfer pricing adjustments. If excess money is not repatriated within that period, imputed per annum interest income is computed using currency-specific benchmarks: the State Bank of India one year marginal cost of funds lending rate as of the first of April plus a margin for rupee-denominated transactions, and the six month London Interbank Offered Rate as of the prior September plus a margin for foreign currency transactions. 'International transaction' is as per section 92B.
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Provisions expressly mentioned in the judgment/order text.
Secondary adjustment interest computation requires repatriation deadline; failure triggers imputed interest based on currency-specific benchmarks.
Secondary adjustments under section 92CE require repatriation of excess funds within a uniform ninety-day period from specified triggering events tied to primary transfer pricing adjustments. If excess money is not repatriated within that period, imputed per annum interest income is computed using currency-specific benchmarks: the State Bank of India one year marginal cost of funds lending rate as of the first of April plus a margin for rupee-denominated transactions, and the six month London Interbank Offered Rate as of the prior September plus a margin for foreign currency transactions. "International transaction" is as per section 92B.
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