29. Insertion of new section 97A in the principal enactment

The following new section is hereby inserted immediately after section 97 of the principal enactment and shall have effect as section 97A of that enactment :-

97A. Where an Assessor is of opinion that any transaction between the members of a group of companies which has no economic substance, has resulted in a tax benefit to any member of the group or a loss from any trade or business to one or more of such members, which can be claimed as a deduction under

“Assessors power to disregard certain transactions between the members of a group of companies.

Inland Revenue (Amendment)

section 29, such transaction shall be desregarded and the relevant persons shall be assessed accordingly.

For the purposes of this section “group of companies” means a parent company and all its subsidiaries where the parent company has one or more subsidiaries and such subsidiaries are controlled by the parent company either by controlling the composition of the Board of

Directors of such subsidiary or by holding more than half in nominal value of the equity share capital of such subsidiary.”.