Treatment of connected person and accommodating party - (New) Section 182 / (Old) Section 99

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.... by disregarding any corporate structure. Meaning of Important Term (a) The Meaning of "Accommodating party" has been defined under section 184(1). "accommodating party" means a party to an arrangement, if the main purpose of the direct or indirect participation of that party in the arrangement, in whole or in part, is to obtain, directly or indirectly, a tax benefit (but for the provisions of this Chapter) for the assessee whether or not the party is a connected person in relation to any party to the arrangement; (b) The Meaning of "Arrangement" has been defined under section 184(2). "Arrangement" means any step in, or a part or whole of, any transaction, operation, scheme, agreement or understanding, whether enforc....

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....er, if the person is a firm or association of persons or body of individuals; • (d) any member of the Hindu undivided family or any relative of such member, if the person is a Hindu undivided family; • (e) any individual who has a substantial interest in the business of the person or any relative of such individual; • (f) a company, firm or an association of persons or a body of individuals, whether incorporated or not, or a Hindu undivided family having a substantial interest in the business of the person or any director, partner, or member of the company, firm or association of persons or body of individuals or family, or any relative of such director, partner or member; • (g) a company,....

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....son referred to in items (B) to (F); and • (ii) for a Hindu undivided family, any member thereof; Under Section 99 of the Income Tax Act, 1961 [ Upto 31.03.2026 ] • As per section 99, for the purposes of this Chapter X-A, in determining whether a tax benefit exists,- • (i) the parties who are connected persons in relation to each other may be treated as one and the same person; • (ii) any accommodating party may be disregarded; • (iii) the accommodating party and any other party may be treated as one and the same person; • (iv) the arrangement may be considered or looked through by disregarding any corporate structure. Meaning of Important Term ....

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....son, or family or any relative of such director, partner or member;  • (h) any other person who carries on a business, if-  • (i) the person being an individual, or any relative of such person, has a substantial interest in the business of that other person; or  • (ii) the person being a company, firm, association of persons, body of individuals, whether incorporated or not, or a Hindu undivided family, or any director, partner or member of such company, firm or association of persons or body of individuals or family, or any relative of such director, partner or member, has a substantial interest in the business of that other person. (b) The Term "Relative" is defined in the Expl....