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of <h1>Arrangements Lacking Commercial Substance Under Section 97(1)(c) Trigger GAAR for Tax Avoidance Schemes</h1> An arrangement is deemed to lack commercial substance under Section 97(1)(c) if it involves the location of an asset, transaction, or residence without substantial commercial purpose, aimed primarily at obtaining a tax benefit. Example scenarios illustrate how General Anti-Avoidance Rules (GAAR) can be invoked when arrangements lack commercial substance. In one case, a company uses a subsidiary in a non-tax jurisdiction to avoid tax on interest income. In another, a joint venture structure is used to gain tax treaty benefits, lacking commercial substance. GAAR may be invoked when the primary purpose is tax avoidance and no substantial business purpose exists.
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