On 30 September 2019, the Central Board of Direct Taxes (CBDT) has amended rule 10CB which provide for computation of interest income relating to secondary adjustments. The changes remove anomalies and clarify the compliance and computational aspects of the secondary adjustment provisions, particularly those arising following the conclusion of an advance pricing agreement (APA) with the tax authorities or a resolution reached under a mutual agreement procedure (MAP) in an applicable tax treaty.
Under Rule 10CB(1), a uniform time limit of 90 days, starting from different dates, is prescribed for repatriation of excess money. This is done in order to provide for uniform treatment in respect of the different types/situations of primary adjustments specified under sub-section (1) of section 92CE.
