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of <h1>Section 97(4) Explores Commercial Substance in Tax Arrangements Under GAAR; Addresses Concerns from Vodafone Case Interpretation</h1> Section 97(4) of the Income Tax Act addresses whether an arrangement lacks commercial substance, with specific provisions under the General Anti-Avoidance Rule (GAAR). It clarifies that certain factors, such as the duration of the arrangement, tax payments, and exit routes, are relevant but insufficient alone to determine commercial substance. Concerns were raised about these provisions conflicting with the Supreme Court's observations in the Vodafone case, which emphasized a holistic approach to foreign direct investments, considering factors like investment duration, business operations, and revenue generation. The Court stressed the importance of identifying the dominant purpose of a scheme to assess its legitimacy.
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