Exception of General Anti Avoidance Rule [ Rule 10U ]
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....te, to all the parties to the arrangement does not exceed a sum of ₹ 3 crore; (b) a Foreign Institutional Investor, - (i) who is an assessee under the Act; (ii) who has not taken benefit of an agreement referred to in section 90 or section 90A as the case may be; and (iii) who has invested in listed securities, or unlisted securities, with the prior permission of the competent author....
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....espect of the tax benefit obtained from the arrangement on or after the 1st day of April, 2017. (3) For the purposes of this rule,- (i) "Foreign Institutional Investor" shall have the same meaning as assigned to it in the Explanation to section 115AD; (ii) "off shore derivative instrument" shall have the same meaning as assigned to it in the Securities and Exchange Board o....