Consequences of impermissible avoidance arrangement - (New) Section 181 / (Old) Section 98

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.... an arrangement is declared to be an impermissible avoidance arrangement, then, the consequences, in relation to tax, of the arrangement, including denial of tax benefit or a benefit under a tax treaty, shall be determined, in the manner as deemed appropriate in the circumstances of the case. Specific Powers to Neutralize Tax Avoidance [ Section 181(2) ] The consequences of an arrangement de....

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....• (i) any accrual, or receipt, of a capital nature or revenue nature; or • (ii) any expenditure, deduction, relief or rebate; • (f) treating- • (i) the place of residence of any party to the arrangement; or • (ii) the situs of an asset or of a transaction, at a place other than the place of residence, location of the asset or locat....

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....rrangement, then, the consequences, in relation to tax, of the arrangement, including denial of tax benefit 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, t....

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....ent; or • (ii) the situs of an asset or of a transaction,  at a place other than the place of residence, location of the asset or location of the transaction as provided under the arrangement; or • (g) considering or looking through any arrangement by disregarding any corporate structure. [ Section 98(1) ] • It has been provided that  ....