https://www.taxtmi.com/caselaws?id=777616 GAAR under Section 96 applies only where an arrangement between two or more parties has specified avoidance attributes, such as non-arm's length rights, misuse or abuse of the Act, lack of commercial substance, or means not ordinarily used for bona fide purposes. The article notes that share transactions were carried out through stock exchange and DMAT accounts, the Department did not establish a nexus with known persons or material beyond timing, and the assessee's investment portfolio and return filings supported a bona fide investment pattern. On that basis, the presumption under Section 96(2) was not independently substantiated, and the reported conclusion is that the transactions did not amount to an impermissible avoidance arrangement. en-us Fri, 22 Aug 2025 00:00:00 +0530 Tue, 02 Sep 2025 08:01:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777616 GAAR under Section 96 applies only where an arrangement between two or more parties has specified avoidance attributes, such as non-arm's length rights, misuse or abuse of the Act, lack of commercial substance, or means not ordinarily used for bona fide purposes. The article notes that share transactions were carried out through stock exchange and DMAT accounts, the Department did not establish a nexus with known persons or material beyond timing, and the assessee's investment portfolio and return filings supported a bona fide investment pattern. On that basis, the presumption under Section 96(2) was not independently substantiated, and the reported conclusion is that the transactions did not amount to an impermissible avoidance arrangement. Case-Laws Income Tax Fri, 22 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777616