https://www.taxtmi.com/manuals?id=4435 Section 97(4) specifies three factors-period of the arrangement, payment of taxes under the arrangement, and availability of an exit route-that may be relevant but are not sufficient to determine whether an arrangement lacks commercial substance. A holistic assessment, examining the life of the business, business operations, generation of taxable revenues, timing and continuity at exit, and the scheme's dominant purpose, is necessary to identify whether a structure is colorable or artificial. en-us Sat, 20 Jan 2024 14:02:00 +0530 Tue, 23 Jan 2024 11:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/manuals?id=4435 Section 97(4) specifies three factors-period of the arrangement, payment of taxes under the arrangement, and availability of an exit route-that may be relevant but are not sufficient to determine whether an arrangement lacks commercial substance. A holistic assessment, examining the life of the business, business operations, generation of taxable revenues, timing and continuity at exit, and the scheme's dominant purpose, is necessary to identify whether a structure is colorable or artificial. Manuals Income Tax Sat, 20 Jan 2024 14:02:00 +0530 https://www.taxtmi.com/manuals?id=4435