Schedule TPSA – Details of Tax on Secondary Adjustments as per Section 92CE(2A) AY 2026-27
‘Schedule TPSA’ in the Income Tax Return (ITR) form pertains to details of tax on secondary adjustments under section 92CE(2A) of the Income-tax Act, 1961. This schedule is to be filled when a taxpayer has opted under section 92CE(2A) to pay tax on excess money arising from primary transfer pricing adjustments, where the money has not been repatriated within the prescribed time.
The schedule seeks a declaration of the total amount of such primary adjustments made across all assessment years for which the repatriation requirement has not been met. The tax liability is then calculated based on the applicable rates, which includes 18% additional income tax on the unrepatriated amount, a surcharge of 12% on the additional income tax, and health and education cess on the aggregate of the two.
The total additional tax payable is computed accordingly. After this, any tax already paid is mentioned and subtracted to arrive at the net tax payable. The second half of the schedule captures the payment details, including the dates of deposit, bank and branch name, BSR code, challan serial number, and the amount deposited across a maximum of six transactions.
Section 92CE of the Income-tax Act, 1961
Rule 10CB of the Income-tax Rules, 1962
A secondary adjustment arises when: the assessee makes a primary adjustment (suo motu, made by AO accepted by assessee, under an APA, under safe harbour rules, or via mutual agreement procedure) and the adjustment results in excess money being available with the associated enterprise.
Secondary adjustments are not required if the primary adjustment is ≤ Rs. 1 crore. If the excess money is not repatriated to India within the prescribed time, it is treated as an advance to the associated enterprise, and interest is computed thereon. Alternatively, the assessee can pay 18% additional tax on the excess money, which is treated as final tax, with no further credit or deduction allowed, and in such case, secondary adjustment and interest computation are not required.
This schedule applies to ITR-3, ITR-5 and ITR-6.