Presumption of purpose: arrangements and constituent steps are deemed made to obtain tax benefits unless rebutted by the taxpayer. An arrangement is presumed entered into or carried out for the main purpose of obtaining a tax benefit unless the person obtaining the benefit proves otherwise. A step or part of an arrangement is similarly presumed to have been undertaken for the main purpose of obtaining a tax benefit, even if the whole arrangement's main purpose is not to obtain a tax benefit.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Presumption of purpose: arrangements and constituent steps are deemed made to obtain tax benefits unless rebutted by the taxpayer.
An arrangement is presumed entered into or carried out for the main purpose of obtaining a tax benefit unless the person obtaining the benefit proves otherwise. A step or part of an arrangement is similarly presumed to have been undertaken for the main purpose of obtaining a tax benefit, even if the whole arrangement's main purpose is not to obtain a tax benefit.
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