The Income Tax Department has come out with rules for operationalising the provisions of secondary adjustment in books of accounts to reflect actual allocation of profits between a company and its arm.The Finance Act 2017 has inserted Section 92CE in the I-T Act to give effect to the secondary adjustment norms, which are based on OECD's transfer pricing guidelines for multinational enterprises and tax administrations.It is also provided that where the excess money available with the associated enterprise on primary adjustment is not repatriated to India within the prescribed time, it shall be deemed to be an advance made by the assessee to such associated enterprise.

Source - http://economictimes.indiatimes.com