What are the 'specified domestic transactions' which are subject to transfer pricing provisions ?
CS Professional · Advanced Tax Laws and Practice · PYQS · June 2015
What are the 'specified domestic transactions' which are subject to transfer pricing provisions ?
Answer & Explanation:
Section 92BA, has been added in Transfer Price Code by Finance Act, 2012 which provides that 'Specified domestic transaction' in case of an assessee means any of the following transactions, not being an international transaction, namely:- Any expenditure in respect of which payment has been made or is to be made to a person referred to in clause (b) of sub-section (2) of section 40A; Any transaction referred to in section 80A; Any transfer of goods or services referred to in sub-section (8) of section 80-IA; Any business transacted between the assessee and other person as referred to in sub-section (10) of section 80-IA; Any transaction, referred to in any other section under Chapter VI-A or section 10AA, to which provisions of sub-section (8) or sub-section (10) of section 80-IA are applicable; or Any other transaction as may be prescribed, and where the aggregate of such transactions entered into by the assessee in the previous year exceeds a sum of five crore rupees. Thus, a specified domestic transaction means a transaction which is covered by criteria as given in section 92BA and the aggregate value of such transactions exceed ₹5 crore in a year.
Topics: Income Tax
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