Lack of commercial substance can trigger GAAR deeming where arrangements affect only tax benefits, not business risks or cash flows. An arrangement is deemed to lack commercial substance if it does not have a significant effect on the business risks or net cash flows of any party to the arrangement, apart from any effect attributable solely to the tax benefit obtainable under the relevant Chapter; this deeming serves as an alternate condition to identify impermissible avoidance arrangements under the General Anti-Avoidance Rule.