For the purposes of this section and sections 92, 92C, 92D and 92E, "specified domestic transaction" in case of an assessee means any of the following transactions, not being an international transaction, namely:—
(i) 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;
(ii) any transaction referred to in section 80A;
(iii) any transfer of goods or services referred to in sub-section (8) of section 80-IA;
(iv) any business transacted between the assessee and other person as referred to in sub-section (10) of section 80-IA;
(v) 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
(vi) 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.]
02 August 2025
Great questions! Here's a clear explanation on **Specified Domestic Transactions (SDT)** under Section 92BA:
1. **Loan taken from associates** — Yes, loans or advances from related parties (associates) are generally considered specified domestic transactions if they fall under any of the transaction types listed (like payments to related parties under section 40A(2)(b)). So loans from associates can be SDTs.
2. **₹5 Crore threshold** — This limit is **aggregate of all specified domestic transactions combined in the previous year** — not per associate. So if the total value of all your SDTs exceeds ₹5 crore, transfer pricing provisions and documentation requirements apply.
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### To summarize:
* All SDTs combined (like loans, payments, transfer of goods/services, etc.) exceeding ₹5 crore trigger transfer pricing compliance. * The threshold is overall, not per related party.
If you want, I can help you identify whether your specific transactions qualify as SDT or draft notes on compliance. Would you like that?
CAclubindia
