General anti-avoidance rule: exclusions for specified investor arrangements and pre-reference notice plus structured referral procedure. The rules add Chapter X-A governing the General Anti-Avoidance Rule, exclude certain arrangements from its application (including small aggregate tax benefits, specified Foreign Institutional Investor investments, non-resident investments via offshore derivative instruments into FIIs, and certain pre-cutoff transfers) while preserving application to tax benefits obtained from a later operative date; they define key terms, require AO notice to the assessee and a prescribed Form No.3CEG reference to the Commissioner with specified contents, prescribe Commissioner forms (3CEH, 3CEI) and impute time limits for Commissioner actions.
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Provisions expressly mentioned in the judgment/order text.
General anti-avoidance rule: exclusions for specified investor arrangements and pre-reference notice plus structured referral procedure.
The rules add Chapter X-A governing the General Anti-Avoidance Rule, exclude certain arrangements from its application (including small aggregate tax benefits, specified Foreign Institutional Investor investments, non-resident investments via offshore derivative instruments into FIIs, and certain pre-cutoff transfers) while preserving application to tax benefits obtained from a later operative date; they define key terms, require AO notice to the assessee and a prescribed Form No.3CEG reference to the Commissioner with specified contents, prescribe Commissioner forms (3CEH, 3CEI) and impute time limits for Commissioner actions.
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