Impermissible avoidance arrangement defined as transactions aimed at securing tax benefits, triggering GAAR presumptions and reverse onus.

An impermissible avoidance arrangement is one whose main purpose is to obtain a tax benefit and which (a) creates non-arm's-length rights or obligations; (b) results in misuse or abuse of the Act; (c) lacks commercial substance or is deemed to lack it under section 180; or (d) is carried out by means not ordinarily used for bona fide purposes. A rebuttable presumption requires the assessee to disprove that a step or part of an arrangement with a main purpose of obtaining a tax benefit implies the whole arrangement was so entered into.

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