19 November 2012
Sec. 92BA provides for the applicability of the Transfer Pricing Regulations to certain Domestic Transactions between the related residnt parties for the purpose of computation of income, disallowance of expenses etc.
The provision has been inserted to avoid the practices of claiming the excessive deductions by the unit enjoying the Tax Holiday, by claiming the excess expenditures in respect of the transactions with the related parties etc.
As per the present provisions of Sec. 92BA, it can be concluded that the Specified Domestic Transactions covers only the transactions of income and expenditure and not the assets and liabilities.
10 November 2013
There is a lack of clarity on the issue, however my personal feeling is that capital asset purchased on which depreciation is being claimed should be reported in Audit Certificate under Transfer Pricing.
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