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of <h1>Arrangement mainly aimed at tax benefit deemed impermissible under Section 97 for lack of commercial substance</h1> An impermissible avoidance arrangement is one whose main purpose is obtaining a tax benefit and which (a) creates rights or obligations not typical between arm's-length parties, (b) results in misuse or abuse of the tax law, (c) lacks commercial substance or is deemed to lack it under section 97, or (d) is entered into or carried out by means or in a manner not ordinarily used for bona fide purposes. If a step or part of an arrangement has the main purpose of obtaining a tax benefit, the arrangement is presumed to have been entered into for that main purpose unless the taxpayer proves otherwise.
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