Specified Domestic Transactions
Even purely domestic dealings can trigger transfer pricing compliance in India when they fall within Section 92BA. We identify the applicable transactions, test the ₹20 crore threshold and prepare defensible benchmarking and documentation.
Direct Answer
Specified Domestic Transactions under Section 92BA are eligible domestic dealings—principally transactions connected with profit-linked tax deduction provisions—that become subject to transfer pricing rules when their aggregate value exceeds ₹20 crore in a financial year.
What is a Specified Domestic Transaction?
Specified Domestic Transactions India rules extend the arm's length principle to selected domestic transactions that are not international transactions. Section 92BA defines the covered categories and applies only where the aggregate value of those transactions exceeds ₹20 crore during the relevant previous year.
The current scope is narrower than the original domestic transfer pricing regime. Ordinary payments to domestic related parties are not automatically SDTs merely because the parties are related. The principal exposure now arises where transactions affect profits eligible for deduction under provisions such as Section 80A or Section 80-IA, including transfers of goods or services between eligible and non-eligible businesses of the same taxpayer or arrangements with closely connected persons.
The objective is to prevent excessive profits from being shifted into a tax-advantaged undertaking or eligible business through non-arm's-length pricing. The transaction must therefore be tested using prescribed transfer pricing methods, supported by contemporaneous documentation and reported in Form 3CEB where applicable.
Who this applies to
Indian businesses operating units or undertakings that claim profit-linked deductions, infrastructure or eligible-business incentives, or other benefits covered by the relevant provisions.
Exposure can arise within the same legal entity, between closely connected persons or through domestic arrangements expressly brought within Section 92BA.
Common SDT categories
We focus on the categories that remain within the current Section 92BA framework rather than treating every domestic related-party payment as an SDT.
Eligible Business Transfers
Transfers of goods or services between an eligible business and another business of the same taxpayer, including captive supply, shared resources and common facility arrangements.
Closely Connected Persons
Transactions between an eligible business and a closely connected person where the arrangement may produce more than ordinary profits in the tax-incentivised undertaking.
Profit-Linked Deduction Cases
Transactions relevant to deductions governed by Section 80A, Section 80-IA and connected provisions where market value or arm's length conditions must be demonstrated.
Other Prescribed Transactions
Any additional domestic transaction category expressly prescribed under Section 92BA or linked statutory provisions for the relevant assessment year.
Transactions commonly requiring closer review
Internal transfers of power, utilities, raw materials, finished goods, technical services, management support, shared infrastructure, employee resources or common costs may affect the profit of an eligible undertaking. The accounting entry, internal invoice and allocation key should reflect market value and actual economic contribution.
How we approach every SDT engagement
Our process separates genuine Section 92BA exposure from ordinary domestic transactions and creates a clear audit trail from applicability through Form 3CEB reporting.
Threshold Testing
We identify all transactions falling within the statutory categories, reconcile their values and test whether the aggregate exceeds ₹20 crore for the relevant financial year.
Transaction Categorisation
Each arrangement is mapped to the applicable provision, eligible undertaking and counterparty. We distinguish covered SDTs from ordinary domestic related-party transactions.
Benchmarking
We select the most appropriate method, test market value and use reliable internal prices, external comparables, cost-based analysis or profitability benchmarks as appropriate.
Documentation & 3CEB
We prepare the SDT analysis, transaction schedules and supporting documentation, then coordinate accurate reporting in Form 3CEB under Section 92E.
SDT exposure is easy to miss — we don't miss it
Accurate Applicability
We apply the current Section 92BA scope and avoid over-reporting ordinary domestic related-party transactions that no longer fall within the definition.
Domestic Comparables
We use internal data and Indian financial databases to support market value, margins, allocation keys and arm's length outcomes.
Integrated Filing
SDT documentation is aligned with financial statements, deduction claims, tax audit disclosures and any international transfer pricing filings.
Common questions
Not sure if SDT rules apply to you?
We'll assess your domestic transaction exposure and ₹20 crore threshold.
Related: International Transaction TP · TP Documentation · Benchmarking & Comparability