Computation of interest income pursuant to secondary adjustments
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....,- (i) from the due date of filing of return under sub-section (1) of section 139 of the Act where primary adjustments to transfer price has been made suo-moto by the assessee in his return of income; (ii) from the date of the order of Assessing Officer or the appellate authority, as the case may be, if the primary adjustments to transfer price as determined in the aforesaid orde....
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.... option exercised by the assessee as per the safe harbour rules under section 92CB;or ^4[(v) from the date of giving effect by the Assessing Officer under rule 44H to the resolution arrived at under mutual agreement procedure, where the primary adjustment to transfer price is determined by such resolution under a Double Taxation Avoidance Agreement entered into under section 90 or section....
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....thereof which is not repatriated- (a) in cases referred to in clause (i), in sub-clause(a) of clause (iii) and clause (iv) of sub rule(1), from the due date of filing of return under sub-section (1) of section 139 of the Act; (b) in cases referred to in clause(ii) of sub-rule(1), from the date of the order of Assessing Officer or the appellate authority, as the case may be; ....
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....f the previous year in which such international transaction was undertaken and the "telegraphic transfer buying rate" shall have the same meaning as assigned in the Explanation to rule 26.] ************** NOTES:- 1. Inserted vide Notification No. 52/2017 dated 15-06-2017 2. Substituted vide Notification No. 76/2019 dated 30-09-2019 before it was read as, ....
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