https://www.taxtmi.com/circulars?id=55665 GAAR applies alongside SAAR and treaty anti abuse rules, guided by the main purpose test under section 96; treaty LOB can preclude GAAR where avoidance is addressed. Grandfathering protects pre 1 April 2017 investments in specified convertible instruments and related bonus/split shares, but excludes standalone leases and loans. Advance Rulings and court sanctioned arrangements preclude GAAR. Invocation requires Principal Commissioner/Commissioner vetting and an Approving Panel review; GAAR disregards covered arrangements, assesses Indian jurisdictional tax benefit per assessment year, does not mandate cross taxpayer corresponding adjustments, and offers no blanket penalty exemption. en-us Fri, 27 Jan 2017 00:00:00 +0530 Fri, 27 Jan 2017 18:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/circulars?id=55665 GAAR applies alongside SAAR and treaty anti abuse rules, guided by the main purpose test under section 96; treaty LOB can preclude GAAR where avoidance is addressed. Grandfathering protects pre 1 April 2017 investments in specified convertible instruments and related bonus/split shares, but excludes standalone leases and loans. Advance Rulings and court sanctioned arrangements preclude GAAR. Invocation requires Principal Commissioner/Commissioner vetting and an Approving Panel review; GAAR disregards covered arrangements, assesses Indian jurisdictional tax benefit per assessment year, does not mandate cross taxpayer corresponding adjustments, and offers no blanket penalty exemption. Circulars Income Tax Fri, 27 Jan 2017 00:00:00 +0530 https://www.taxtmi.com/circulars?id=55665