Need Tally
for Clients?

Contact Us! Here

  Tally Auditor

License (Renewal)
  Tally Gold

License Renewal

  Tally Silver

License Renewal
  Tally Silver

New Licence
  Tally Gold

New Licence
 
Open DEMAT Account with in 24 Hrs and start investing now!
« Transfer Pricing »
Open DEMAT Account in 24 hrs
 I T department keeps tolerance range for transfer pricing unchanged
 India retains transfer pricing tolerance range for 2019 20
 PCIT rightly directed the Bank of India s case to Transfer Pricing Officer for determining ALP ITAT
 Key Highlights Of The 2nd Edition Of KSA Transfer Pricing Guidelines
 ITAT deletes Penalty since Assessee applied Transfer Pricing Provisions with Good faith and Due Diligence
 Change in transfer pricing regulations to help MNCs
 National High Speed Rail Corporation Limited, New Delhi, Delhi
 Deals of the day-Mergers and acquisitions September 3, 2019
 Transfer pricing documentation due by year-end
 Transfer pricing amendments – a step towards certainty
 key international tax and transfer pricing developments

CBDT notifies secondary adjustment rule in transfer pricing
June, 20th 2017

The Income Tax Department has come out with rules for operationalising the provisions of secondary adjustment in books of accounts to reflect actual allocation of profits between a company and its arm.

The Finance Act 2017 has inserted Section 92CE in the I-T Act to give effect to the secondary adjustment norms, which are based on OECD's transfer pricing guidelines for multinational enterprises and tax administrations.

It is also provided that where the excess money available with the associated enterprise on primary adjustment is not repatriated to India within the prescribed time, it shall be deemed to be an advance made by the assessee to such associated enterprise.

The tax department has now notified the time-limit for repatriation of excess money and the rate of interest to be applied for computing the income in case of failure to repatriate the excess money within the prescribed time-limit.

"The time-limit of 90 days for repatriation of excess money shall begin only when the primary adjustments exceeding Rs 1 crore made in respect of Assessment Year 2017-18 or later, attains finality.

"Where the transfer pricing order is appealed against by the taxpayer, the time-limit for repatriation shall commence only after the appeal is finalised by the appellate authority," the tax department said in a statement.

Home | About Us | Terms and Conditions | Contact Us
Copyright 2024 CAinINDIA All Right Reserved.
Designed and Developed by Ritz Consulting