Impermissible avoidance arrangement.96. (1)An impermissible avoidance arrangement means an arrangement, the main purpose of which is to obtain a tax benefit, and it-
| (a) | - | creates rights, or obligations, which are not ordinarily created between persons dealing at arm's length; |
| (b) | - | results, directly or indirectly, in the misuse, or abuse, of the provisions of this Act; |
| (c) | - | lacks commercial substance or is deemed to lack commercial substance under section 97, in whole or in part; or |
| (d) | - | is entered into, or carried out, by means, or in a manner, which are not ordinarily employed for bona fide purposes. |
(2) An arrangement shall be presumed, unless it is proved to the contrary by the assessee, to have been entered into, or carried out, for the main purpose of obtaining a tax benefit, if the main purpose of a step in,
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