Section 92CE of ITA, 1961 : Section 92Ce: Secondary Adjustment In Certain Cases
ITA, 1961
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Explanation using Example
Imagine a company, IndiaTech Pvt. Ltd., which is based in India and has a subsidiary, EuroTech GmbH, in Germany. IndiaTech sells software services to EuroTech at a price lower than what it charges to unrelated parties. The Indian tax authorities, upon reviewing the transaction, determine that the price charged to EuroTech is not at arm's length and make a primary adjustment to the transfer price, increasing IndiaTech's taxable income.
As per Section 92CE of the Income-ta...
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