Treatment of connected person and accommodating party [ Section 99 ]

Treatment of connected person may be aggregated for tax benefit assessment, allowing disregard of accommodating parties.

For determining whether a tax benefit exists under Chapter X-A, parties who are connected persons may be treated as one and the same person; an accommodating party may be disregarded or treated as one with any other party; and the arrangement may be looked through by disregarding corporate structure. The term 'connected person' covers relatives, directors and their relatives, partners or members of firms or associations, members of Hindu undivided families and persons or entities with a substantial interest in the business, enabling attribution across related individuals and entities.