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CS Professional · Advanced Direct Tax Laws and Practice · Transfer Pricing and General Anti Avoidance Rules (GAAR)

Under section 170 of the Income-tax Act, 2025, the threshold for mandatory secondary adjustment applies where the primary adjustment to the transfer price is:

A secondary adjustment is mandatory where the primary adjustment to the transfer price is one crore rupees or more, provided it arises in one of the listed ways, such as being self-made in the return or accepted by the assessee after an Assessing Officer's adjustment.

  1. ATen lakh rupees or more
  2. BOne crore rupees or moreCorrect
  3. CTen crore rupees or more
  4. DAny amount, with no monetary threshold

Explanation

Section 170(1) requires a secondary adjustment in every case where the primary adjustment is one crore rupees or more and arises in any of the listed situations, such as being made by the assessee in its return or accepted by it from the Assessing Officer. The lower and higher figures are not in the section.

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