Amendment of section 92CE.
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....o shall be inserted and shall be deemed to have been inserted with effect from the 1st day of April, 2018, namely:-- "Provided further that no refund of taxes paid, if any, by virtue of provisions of this sub-section as they stood immediately before their amendment by the Finance (No.2) Act, 2019 shall be claimed and allowed."; (b) in sub-section (2),-- (i) for the words "the excess money which", the words "the excess money or part thereof, as the case may be, which" shall be substituted and shall be deemed to have been substituted with effect from the 1st day of April, 2018; (ii) the following Explanation shall be inserted and shall be deemed to have been inserted with effect from the 1st day of April, 2018, namely:-- "Explanation....
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....ct relating to secondary adjustment in certain cases. Sub-section (1) of the said section, inter alia, provides that the assessee shall make secondary adjustment in case where primary adjustment to transfer price takes place as specified therein. The proviso to said sub-section provides exemption in cases where the amount of primary adjustment made in any previous year does not exceed the threshold limit of one crore rupees; and the primary adjustment is made in respect of an assessment year commencing on or before 1st April, 2016. It is proposed to amend clause (iii) of the said sub-section so as to provide that the secondary adjustment will be applicable where the primary adjustment to transfer price is determined by an advance pricing ....