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Amendment of section 92CE.

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..... ay of April, 2018; (III) after the proviso, the following proviso 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 .....

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..... e, he shall not be required to make secondary adjustment under sub-section (1) and compute interest under sub-section (2) from the date of payment of such tax. . - Clause 30 of the Bill seeks to amend section 92CE of the Incometax Act 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 .....

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..... and subsequent assessment years. It is also proposed to insert sub-section ( 2A ) in the said section so as to provide that where the excess money or part thereof has not been repatriated in time, besides the existing requirement of calculation of interest, the assessee will have the option to pay additional income tax at the rate of eighteen per cent. on such excess money or part thereof. It is also proposed to insert sub-section (2B) so as to provide that the tax on the excess money or part thereof so paid by the assessee under sub-section (2A) shall be treated as the final payment of tax in respect of the excess money or part thereof not repatriated and no further credit therefor shall be claimed by the assessee .....

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