Domestic Transfer Pricing arm's length, even within India's borders.
Specialist domestic transfer pricing advisory for specified domestic transactions under Section 92BA — Section 80-IA / 80-IB transactions, SEZ inter-unit transfers, and related-party domestic dealings, with documentation and Form 3CEB filing.
Domestic transfer pricing was introduced into the Income-tax Act in 2012 to extend the arm's length principle to specified domestic transactions between related parties — primarily where one party enjoys a tax holiday or concessional rate and the other does not. Section 92BA defines the scope, with a turnover threshold of ₹20 crore from related-party SDTs.
Common triggers include transactions of tax-holiday units under Sections 80-IA, 80-IB, and 10AA with their non-holiday associates, transfers between SEZ and non-SEZ units, and certain payments to specified persons under Section 40A(2)(b) before its omission from SDT scope.
We help companies map their SDT exposure, prepare Rule 10D documentation, benchmark inter-unit transactions, and file Form 3CEB covering both international and domestic transactions. Where SDT involves tax-holiday units, the benchmarking is particularly important since adjustments directly hit deduction claims.
Our Domestic Transfer Pricing Services
SDT Scoping
Section 92BA mapping of all specified domestic transactions.
Threshold Assessment
₹20 crore SDT threshold tested annually.
80-IA / 80-IB / 10AA SDT
TP analysis of tax-holiday unit transactions with related parties.
Inter-Unit Transfers
SEZ and non-SEZ inter-unit transfer pricing.
Benchmarking
Domestic benchmarking using ProwessIQ and Capitaline.
Local File for SDT
Rule 10D documentation for SDT transactions.
Form 3CEB Disclosure
Form 3CEB disclosure covering all SDT categories.
Assessment Support
TPO assessment and DRP / CIT(A) representation on SDT.
Our Approach
Trigger Map
All entities, units, and related parties mapped to SDT triggers.
Threshold Test
₹20 crore SDT aggregate threshold tested.
Benchmarking
Inter-unit and related-party benchmarking executed.
Documentation
Rule 10D Local File and Form 3CEB disclosure prepared.
Defence
TPO assessment and onward appeals managed.
Why It Matters
Frequently Asked Questions
Arm's length pricing of specified domestic transactions between related parties under Section 92BA.
₹20 crore aggregate value of specified domestic transactions in a financial year.
No, only transactions specifically listed under Section 92BA qualify as SDTs.
Yes, SDTs must be reported in Form 3CEB along with international transactions.
No, such payments were removed from SDT scope by the Finance Act 2017.
SDT Exposure in Your Group?
Get Section 92BA scoping, threshold tracking, inter-unit benchmarking, and Form 3CEB disclosure done by a specialist Chartered Accountant team.
Review My Domestic TP or call +91 9819 000 511