Impermissible avoidance arrangement: tax consequences confined to the declared part of the arrangement under applicable rules. Tax consequences for an impermissible avoidance arrangement are confined to the portion of the arrangement declared impermissible, so that fiscal effects are determined with reference to that part only and not the arrangement as a whole.
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: tax consequences confined to the declared part of the arrangement under applicable rules.
Tax consequences for an impermissible avoidance arrangement are confined to the portion of the arrangement declared impermissible, so that fiscal effects are determined with reference to that part only and not the arrangement as a whole.
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