Secondary adjustment under Section 92CE:
APrimary adjustment > Rs. 1 crore (specified conditions)
BAlways
COnly non-residents
DOnly when AE refuses repatriation (per relevant Section)
Answer & Solution
Correct answer: A. Primary adjustment > Rs. 1 crore (specified conditions)
1. Section 92CE (FA 2017): secondary adjustment when primary TP adjustment.
2. Conditions: primary > Rs. 1 crore for suo motu, APA, MAP, AO order accepted, safe harbour.
3. If excess not repatriated within 90 days, deemed advance to AE; notional interest taxed.
_Source: ICAI BoS CA Final Paper 7, Ch 24 "Transfer Pricing"_
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