Interest on excess transfer pricing adjustments begins from specified dates depending on APA, assessment orders, or MAP resolutions. Rule 10CB is amended to substitute 'excess money or part thereof,' to define specific commencement dates for interest where primary adjustments follow an APA or MAP resolution or assessing authority orders, and to insert sub-rule (3) charging interest on excess money or part thereof not repatriated from distinct specified dates. The Explanation is replaced to adopt the section 92B meaning of 'international transaction' and to require the telegraphic transfer buying rate on the last day of the previous year for currency conversion.
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.
Interest on excess transfer pricing adjustments begins from specified dates depending on APA, assessment orders, or MAP resolutions.
Rule 10CB is amended to substitute "excess money or part thereof," to define specific commencement dates for interest where primary adjustments follow an APA or MAP resolution or assessing authority orders, and to insert sub-rule (3) charging interest on excess money or part thereof not repatriated from distinct specified dates. The Explanation is replaced to adopt the section 92B meaning of "international transaction" and to require the telegraphic transfer buying rate on the last day of the previous year for currency conversion.
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