General anti-avoidance rule exclusions cover low-tax-benefit arrangements, foreign investment activity, and pre-2017 investment transfers. Chapter XI on the General Anti-Avoidance Rule does not apply where the aggregate tax benefit in a relevant tax year to all parties to an arrangement does not exceed three crore rupees. The rule also excludes specified foreign investment activity, including investments by a Foreign Institutional Investor meeting the stated conditions, investments by a non-resident through offshore derivative instruments or otherwise in such an investor, and income from transfer of investments made before 1 April 2017. Chapter XI applies to arrangements for tax benefit obtained on or after 1 April 2017, subject to defined terms.
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Provisions expressly mentioned in the judgment/order text.
General anti-avoidance rule exclusions cover low-tax-benefit arrangements, foreign investment activity, and pre-2017 investment transfers.
Chapter XI on the General Anti-Avoidance Rule does not apply where the aggregate tax benefit in a relevant tax year to all parties to an arrangement does not exceed three crore rupees. The rule also excludes specified foreign investment activity, including investments by a Foreign Institutional Investor meeting the stated conditions, investments by a non-resident through offshore derivative instruments or otherwise in such an investor, and income from transfer of investments made before 1 April 2017. Chapter XI applies to arrangements for tax benefit obtained on or after 1 April 2017, subject to defined terms.
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