https://www.taxtmi.com/manuals?id=4443 An arrangement is deemed to lack commercial substance under Section 97(1)(b) where it includes round trip financing, an accommodating party, elements that offset each other, or disguises the value, source, location, ownership or control of funds. Round trip financing covers series of transfers lacking substantial commercial purpose apart from tax benefit, irrespective of traceability or sequence. An accommodating party participates mainly to secure a tax benefit for the taxpayer. Such features permit disregarding intermediaries, reattributing income, denying treaty benefits, and disallowing related deductions. en-us Tue, 23 Jan 2024 18:03:00 +0530 Tue, 23 Jan 2024 18:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/manuals?id=4443 An arrangement is deemed to lack commercial substance under Section 97(1)(b) where it includes round trip financing, an accommodating party, elements that offset each other, or disguises the value, source, location, ownership or control of funds. Round trip financing covers series of transfers lacking substantial commercial purpose apart from tax benefit, irrespective of traceability or sequence. An accommodating party participates mainly to secure a tax benefit for the taxpayer. Such features permit disregarding intermediaries, reattributing income, denying treaty benefits, and disallowing related deductions. Manuals Income Tax Tue, 23 Jan 2024 18:03:00 +0530 https://www.taxtmi.com/manuals?id=4443