https://www.taxtmi.com/manuals?id=4444 An arrangement is deemed to lack commercial substance where the location of an asset, transaction, or a party's residence is chosen without substantial commercial purpose other than obtaining a tax benefit; where the main purpose is tax avoidance and a tainted element exists, GAAR permits disregarding intermediaries and denying treaty or domestic tax benefits even if the intermediary has nominal office or employees. en-us Tue, 23 Jan 2024 18:09:00 +0530 Tue, 23 Jan 2024 18:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/manuals?id=4444 An arrangement is deemed to lack commercial substance where the location of an asset, transaction, or a party's residence is chosen without substantial commercial purpose other than obtaining a tax benefit; where the main purpose is tax avoidance and a tainted element exists, GAAR permits disregarding intermediaries and denying treaty or domestic tax benefits even if the intermediary has nominal office or employees. Manuals Income Tax Tue, 23 Jan 2024 18:09:00 +0530 https://www.taxtmi.com/manuals?id=4444