https://www.taxtmi.com/caselaws?id=183575 The Ramsay principle, as extended in Furniss v Dawson, applies only on a true construction of the charging provision where the relevant steps form a preordained composite transaction intended to operate as one scheme. A tax-avoidance step is disregarded only if, at the material time, the later disposal was in practical terms part of the same indivisible arrangement and not merely contemplated. A mere tax-saving motive, or a preparatory step followed by a later independent sale, is insufficient. On the facts discussed, the Bowater and Gregory transactions failed the composite-transaction test because of genuine interruption and uncertainty, and the Craven transaction also lacked sufficient certainty and interdependence. en-us Mon, 16 May 1988 00:00:00 +0530 Tue, 14 Jun 2016 17:51:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=183575 The Ramsay principle, as extended in Furniss v Dawson, applies only on a true construction of the charging provision where the relevant steps form a preordained composite transaction intended to operate as one scheme. A tax-avoidance step is disregarded only if, at the material time, the later disposal was in practical terms part of the same indivisible arrangement and not merely contemplated. A mere tax-saving motive, or a preparatory step followed by a later independent sale, is insufficient. On the facts discussed, the Bowater and Gregory transactions failed the composite-transaction test because of genuine interruption and uncertainty, and the Craven transaction also lacked sufficient certainty and interdependence. Case-Laws Income Tax Mon, 16 May 1988 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=183575