Impermissible avoidance arrangements attract tax consequences only for the identified part, reflecting partial application of GAAR consequences.

Where only a part of an arrangement is treated as an impermissible avoidance arrangement, the tax consequences are to be determined only with reference to that part. The anti-avoidance consequence mechanism is therefore confined to the identified impermissible component rather than extended to the whole arrangement. The same principle is reflected under Rule 127 read with section 181 and under the earlier Rule 10UA read with section 98(1).

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