Avoidance of income-tax by transactions resulting in transfer of income to non-residents.

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...., if—            (a) the income accrues by virtue of a transfer of any asset by the person, either alone or in conjunction with associated operations, directly or indirectly, to the non-resident;           (b) the person —           &nbs....

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....e form of income or not, to enure for the benefit of the person;          (b) the accrual or receipt of the income operates to increase the value to the person of any assets held by him or for his benefit;          (c) the person receives, or is entitled to receive, at any time any benefit provided, or to be prov....

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....ad to—         (a) the substantial result and effect of the transfer and any associated operations; and         (b) all benefits which may at any time accrue to such person as a result of the transfer and any associated operations, irrespective of the nature or form of the benefits.     (4) The provisio....