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Clause - 015 - Amendment of section 40A.
Clause 15 of the Bill seeks to amend section 40A of the lncome -tax Act relating to expenses or payments not deductible in certain circumstances.
It is also proposed to amend the proviso to clause (a) of sub-section (2) which is consequential to the amendments proposed in section 92BA.
Restriction on deduction for specified domestic transactions removes arm's length deduction and subjects payments to disallowance rules. The Finance Bill 2017 amends section 40A to withdraw automatic deductibility for payments under specified domestic transactions made at Arm's Length Price; such payments are now subject to the disallowance rules of section 40A(2). The amendment also alters the proviso to clause (a) of sub section (2) consequential to the transfer pricing provision, aligning domestic specified transaction treatment with the transfer pricing framework and applying retrospectively as provided in the Bill.
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