Commercial substance: statutory factors are relevant but not decisive; holistic assessment of arrangement life and exit required. Section 97(4) specifies three factors-period of the arrangement, payment of taxes under the arrangement, and availability of an exit route-that may be relevant but are not sufficient to determine whether an arrangement lacks commercial substance. A holistic assessment, examining the life of the business, business operations, generation of taxable revenues, timing and continuity at exit, and the scheme's dominant purpose, is necessary to identify whether a structure is colorable or artificial.