Domestic transfer pricing

Hello,

Specified domestic transactions cover any expenditure in respect of which payment has been made or is to be made to a person referred to in Section 40A(2)(b). Now my query is whether only expenditure is to be looked at irrespective of the income from the persons covered in section 40A(2)(b)?

Or whether net of income and expenditure is to be considered for the SDT?

Kindly advice.