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CA Final · Direct Tax Laws & International Taxation · Provisions to Counteract Unethical Tax Practices

Three Indian concerns, A Ltd, B Ltd and C Ltd, belong to the same group, which has an indirect transfer event. The group wants only A Ltd to furnish Form No. 163 for all. Under Rule 235 of the Income-tax Rules, 2026, which course satisfies the rule?

The group must designate A Ltd to furnish information on behalf of all Indian constituents and convey that designation in writing to the Assessing Officer. Without both steps, B Ltd and C Ltd are not covered by A Ltd's filing under Rule 235.

  1. AGroup designates A Ltd to furnish for all and conveys this in writing to the Assessing OfficerCorrect
  2. BA Ltd may file on its own without any designation, and B and C are automatically covered
  3. CEach concern must file separately, with no exception
  4. DOnly the ultimate holding company may file, even if foreign

Explanation

Rule 235(4) allows one Indian concern to furnish information if the group designated it to do so for all other Indian concerns and the information about the designated concern was conveyed in writing to the Assessing Officer. Without designation and written intimation, the others are not covered.

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