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A company makes a primary transfer-pricing adjustment on its own in its return of income. Under rule 83 of the Income-tax Rules, 2026, within what time must the excess money be repatriated to avoid…

Question and options

A company makes a primary transfer-pricing adjustment on its own in its return of income. Under rule 83 of the Income-tax Rules, 2026, within what time must the excess money be repatriated to avoid the consequences in section 170(2)?

  1. 90 days from the end of the relevant tax year

  2. 90 days from the date the return is actually filed

  3. 30 days from the due date for filing the return

  4. 90 days from the due date for filing the return

Answer and explanation

Correct answer: D - 90 days from the due date for filing the return

Rule 83(1) of the Income-tax Rules, 2026 requires excess money to be repatriated within ninety days of a date that depends on how the primary adjustment arose; for an adjustment made suo motu in the return, it is the due date for furnishing the return under section 263(1) of the Income-tax Act, 2025. The actual filing date does not count, so filing early does not shorten the period.

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