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)
Impermissible avoidance arrangement consequences are limited to the specific part of the arrangement declared impermissible. Where only a part of an arrangement is declared an impermissible avoidance arrangement for the purposes of section 98(1), the tax consequences are determined with reference to that part alone. The rule confines the anti-avoidance consequence to the specific portion of the arrangement found impermissible, rather than extending it to the entire arrangement.
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.
Impermissible avoidance arrangement consequences are limited to the specific part of the arrangement declared impermissible.
Where only a part of an arrangement is declared an impermissible avoidance arrangement for the purposes of section 98(1), the tax consequences are determined with reference to that part alone. The rule confines the anti-avoidance consequence to the specific portion of the arrangement found impermissible, rather than extending it to the entire arrangement.
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