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of <h1>Finance Bill 2019-20 Amends Section 92CE: New Rules for Secondary Adjustments and Taxes on Delayed Repatriation.</h1> The Finance Bill 2019-20 proposes amendments to section 92CE of the Act to improve the secondary adjustment regime in transfer pricing. It clarifies that the conditions regarding the threshold of one crore rupees and primary adjustments up to the assessment year 2016-17 are alternate. The amendments mandate calculating interest on excess money and allow repatriation from non-resident associated enterprises. If repatriation is delayed, an additional 18% tax with a 12% surcharge is applicable. This tax is final, with no credit or deduction allowed. These changes apply retrospectively from April 1, 2018, and prospectively from September 1, 2019.
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