Time period for repatriation of excess money under section 170(2) and computation of interest income under section 170(4) pursuant to secondary adjustments

Time limit (sub-rule 1). Repatriation is due on or before ninety days from the date in column C, depending on how the primary adjustment arose:

Primary adjustment	Ninety days from
Made suo motu by the assessee in the return	Due date for furnishing the return under section 263(1)
Determined in the order of the Assessing Officer or the appellate authority and accepted by the assessee	Date of that order
Determined by an advance pricing agreement (section 168) entered on or before the return due date for the relevant tax year	Due date for furnishing the return under section 263(1)
Determined by an advance pricing agreement entered after the return due date	End of the month in which the agreement was entered into
Option exercised under the safe harbour rules (section 167)	Due date for furnishing the return under section 263(1)
Resolution under a mutual agreement procedure under a Double Taxation Avoidance Agreement (section 159(1) or (2))	Date of the order giving effect to that resolution under rule 121(10)

Imputed interest (sub-rules 2 and 3). If excess money is not repatriated in time, interest is imputed per annum on the amount not repatriated from the date in column C: for a transaction denominated in rupees, at the State Bank of India's one-year marginal cost of funds lending rate on 1 April of the relevant tax year plus 325 basis points; for a transaction in foreign currency, at the reference rate of the currency (rule 89(3)) on 30 September of the relevant tax year plus 300 basis points.

Exchange rate (sub-rule 4). Foreign-currency transactions are converted into rupees at the telegraphic transfer buying rate on the last day of the tax year in which the transaction took place (rule 207).