Part DCA - Safe Harbour Rules for income referred to in clause (i) of sub-section (1) of section 9 chargeable to tax under the head (From Rule 10TI to Rule 10TIC)
General Anti-Avoidance Rule exclusions for low tax benefits, specified investors, and pre-2017 transfer income Chapter X-A on the General Anti-Avoidance Rule does not apply to arrangements where the aggregate tax benefit in the relevant assessment year does not exceed rupees three crore, or to specified Foreign Institutional Investors and certain non-residents investing in such investors. The rule also excludes income from transfer of investments made before 1 April 2017. Chapter X-A nevertheless applies to any arrangement, irrespective of its date, for tax benefit obtained on or after 1 April 2017, subject to the stated carve-out. The rule defines key expressions for this purpose.
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Provisions expressly mentioned in the judgment/order text.
General Anti-Avoidance Rule exclusions for low tax benefits, specified investors, and pre-2017 transfer income
Chapter X-A on the General Anti-Avoidance Rule does not apply to arrangements where the aggregate tax benefit in the relevant assessment year does not exceed rupees three crore, or to specified Foreign Institutional Investors and certain non-residents investing in such investors. The rule also excludes income from transfer of investments made before 1 April 2017. Chapter X-A nevertheless applies to any arrangement, irrespective of its date, for tax benefit obtained on or after 1 April 2017, subject to the stated carve-out. The rule defines key expressions for this purpose.
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