General anti-avoidance rule strengthened to permit declaration of impermissible tax-avoidance arrangements and determine tax consequences.

The Bill revises tax rates, withholding rules and surcharge/cess application; clarifies key definitions and the situs of property and income; tightens and extends various deductions and incentive timeframes; expands transfer-pricing law to include specified domestic transactions with attendant documentation, valuation and penalty consequences; introduces a comprehensive general anti-avoidance rule with a Commissioner referral and Approving Panel process binding on Assessing Officers; extends reopening and limitation rules for offshore assets and reporting failures; establishes new withholding, reporting and penalty regimes, graded search-related penalty provisions, Special Courts for tax offences, and multiple procedural and appellate adjustments, many with specified retrospective or prospective effective dates.

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