Section 92CE Secondary Adjustments Under the Income-tax Act 2025: Rs 1 Crore Threshold, 90-Day Repatriation Window, and the 18 Percent Settlement Option
Section 92CE of the Income-tax Act 2025 requires Indian taxpayers to repatriate excess money from overseas associated enterprises within 90 days of any primary transfer pricing adjustment exceeding Rs 1 crore, failing which deemed interest accrues at SBI 1-year MCLR plus 325 basis points. This advisory covers the Rule 10CB mechanics, Form 3CEB and Form 3CD Clause 30B disclosures, and the 18 percent settlement option for AY 2026-27 compliance.