https://www.taxtmi.com/manuals?id=4443 An arrangement is deemed to lack commercial substance if it satisfies any one of four independent tests: round trip financing, use of an accommodating party, offsetting or cancelling elements, or a transaction that disguises the value, location, source, ownership or control of funds. Round trip financing covers series of transactions in which funds are transferred among parties mainly to obtain a tax benefit, without regard to traceability, sequence, or mode of transfer. An accommodating party is one whose participation is mainly to secure a tax benefit for the assessee, whether or not connected. The term arrangement is defined broadly to cover any step in a transaction, operation, scheme, agreement or understanding. en-us Tue, 23 Jan 2024 18:03:00 +0530 Thu, 09 Jul 2026 18:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/manuals?id=4443 An arrangement is deemed to lack commercial substance if it satisfies any one of four independent tests: round trip financing, use of an accommodating party, offsetting or cancelling elements, or a transaction that disguises the value, location, source, ownership or control of funds. Round trip financing covers series of transactions in which funds are transferred among parties mainly to obtain a tax benefit, without regard to traceability, sequence, or mode of transfer. An accommodating party is one whose participation is mainly to secure a tax benefit for the assessee, whether or not connected. The term arrangement is defined broadly to cover any step in a transaction, operation, scheme, agreement or understanding. Manuals Income Tax Tue, 23 Jan 2024 18:03:00 +0530 https://www.taxtmi.com/manuals?id=4443