Consequences of impermissible avoidance arrangement [ Section 98 ]

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....efit or a benefit under a tax treaty, shall be determined, in such manner as is deemed appropriate, in the circumstances of the case, including by way of but not limited to the following, namely:- * (a) disregarding, combining or recharacterising any step in, or a part or whole of, the impermissible avoidance arrangement; * (b) treating the impermissible avoidance arrangement as if it had not ....