https://www.taxtmi.com/manuals?id=4433 The tainted element test under GAAR requires, along with the purpose of obtaining a tax benefit, one or more statutory tainted elements to make an arrangement impermissible. These include non-arm's length dealings, misuse or abuse of tax law, lack of commercial substance, and arrangements carried out in a manner normally not employed for a bona fide purpose. The text explains that transfer pricing principles may be relevant to the first element, and that treaty-shopping structures lacking commercial substance may attract GAAR. en-us Fri, 19 Jan 2024 18:35:00 +0530 Thu, 09 Jul 2026 16:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/manuals?id=4433 The tainted element test under GAAR requires, along with the purpose of obtaining a tax benefit, one or more statutory tainted elements to make an arrangement impermissible. These include non-arm's length dealings, misuse or abuse of tax law, lack of commercial substance, and arrangements carried out in a manner normally not employed for a bona fide purpose. The text explains that transfer pricing principles may be relevant to the first element, and that treaty-shopping structures lacking commercial substance may attract GAAR. Manuals Income Tax Fri, 19 Jan 2024 18:35:00 +0530 https://www.taxtmi.com/manuals?id=4433