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AI Drafter ✕

Generate professional replies to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.

Step 1 – Issue Identification & Review

The AI analyses your query, notice, order, or uploaded documents and identifies the key issues involved.

• Review the issues identified by the AI
• Add, edit, remove, or refine issues as required


Step 2 – Draft Generation

Once you approve the issues, the AI performs issue-wise legal research and prepares a structured draft response.

• Relevant statutory provisions
• Judicial precedents and Supreme Court, High Court and other citations
• Issue-wise legal analysis
• Practical arguments and supporting content
• Professionally structured draft ready for further review.

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        Income Tax

        Final Report on General Anti Avoidance Rules (GAAR) in Income-tax Act, 1961 Expert Committee (2012)

        January 14, 2013

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        Final Report on General Anti Avoidance Rules (GAAR) in Income-tax Act, 1961 Expert Committee (2012)

        General Anti-Avoidance Rules: limit scope to arrangements with main tax-avoidance purpose, set Rs.3 crore threshold, defer rollout. The Committee recommends limiting GAAR to arrangements whose main purpose is to obtain a tax benefit, inserting a statutory definition of commercial substance, confining GAAR consequences to impermissible parts of arrangements, deferring implementation by three years with a pre-announced effective year, prescribing a Rs. 3 crore monetary threshold (tax only, present-value for deferral), grandfathering existing investments (not arrangements), strengthening AAR and procedural safeguards, constituting an independent five-member Approving Panel, and ensuring SAAR or treaty anti-abuse provisions prevail over GAAR for covered aspects.
                          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.

                                General Anti-Avoidance Rules: limit scope to arrangements with main tax-avoidance purpose, set Rs.3 crore threshold, defer rollout.

                                The Committee recommends limiting GAAR to arrangements whose main purpose is to obtain a tax benefit, inserting a statutory definition of commercial substance, confining GAAR consequences to impermissible parts of arrangements, deferring implementation by three years with a pre-announced effective year, prescribing a Rs. 3 crore monetary threshold (tax only, present-value for deferral), grandfathering existing investments (not arrangements), strengthening AAR and procedural safeguards, constituting an independent five-member Approving Panel, and ensuring SAAR or treaty anti-abuse provisions prevail over GAAR for covered aspects.


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