Domestic TP
Applying the arm's length standard to specified transactions between related parties within India.
Specified Domestic Transactions under Section 92BA extend the transfer pricing regime to certain related-party dealings within India — such as transactions involving units eligible for profit-linked deductions, or payments to specified persons — once they cross the prescribed aggregate threshold. The compliance obligations, including benchmarking and Form 3CEB reporting, largely mirror those for international transactions, but the categories of covered transactions are narrower and specifically defined.
What domestic TP compliance involves
The first step is always confirming whether your related-party transactions actually fall within the specified categories.
- Identifying transactions covered under Section 92BA
- Checking whether the aggregate threshold has been crossed
- Reviewing transactions involving tax-holiday or deduction-eligible units
- Benchmarking payments to specified persons under Section 40A(2)(b)
- Preparing documentation proportionate to transaction value
- Filing Form 3CEB alongside the return where applicable
What this service includes
How we support your domestic TP compliance.
Specified Transaction Identification
Determining which of your intra-India related-party dealings fall under Section 92BA.
Threshold Monitoring
Tracking aggregate transaction value across the year against the prescribed limit.
Benchmarking for Specified Persons
Running comparability analysis for payments covered under Section 40A(2)(b).
Form 3CEB Filing
Preparing and certifying the accountant's report for domestic transactions.
Our process
From initial consultation to completion.
Related Party Mapping
Identifying all related-party transactions within India during the year.
Threshold Assessment
Checking whether the aggregate specified transaction value triggers TP applicability.
Benchmarking & Documentation
Preparing the analysis and documentation for covered transactions.
Certification & Filing
Issuing Form 3CEB and filing it with the return by the due date.
Why domestic TP shouldn't be overlooked
What sets our approach apart.
Often missed because it feels 'internal'
Related-party dealings within the same group or family often get less scrutiny at the time, but the law treats them formally.
Threshold breaches trigger full compliance
Once the aggregate limit is crossed, the entire set of specified transactions needs documentation, not just the transaction that tipped it over.
Deduction claims can be disallowed on top of adjustments
Where tax-holiday units are involved, incorrect pricing can affect the deduction itself, compounding the tax impact.
Domestic TP questions answered
What people ask before engaging us.
Not sure if your domestic transactions are covered?
Let our team help you navigate this process with clarity and confidence.
