Secondary adjustment in certain cases.

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....urn of income; (b) made by the Assessing Officer has been accepted by him; (c) is determined by an advance pricing agreement entered into by him under section 168; (d) is made as per the safe harbour rules made under section 167; or (e) is arising as a result of resolution of an assessment by way of the mutual agreement procedure under an agreement entered into ....

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.... (5) Without prejudice to the provisions of sub-section (2), where the excess money or part thereof has not been repatriated within the prescribed time, the assessee may, at his option, pay additional income-tax at the rate of 18% on such excess money or part thereof, as the case may be. (6) The tax on the excess money or part thereof so paid by the assessee under sub-section (5) shall be treat....

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....e between the arm's length price determined in primary adjustment and the price at which the international transaction has actually been undertaken; (c) "primary adjustment" to a transfer price, means the determination of transfer price as per the arm's length principle resulting in an increase in the total income or reduction in the loss, as the case may be, of the assessee; (d)....