Consequences of impermissible avoidance arrangement.

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Full Text of the Document

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....er a tax treaty, shall be determined, in the manner as deemed appropriate. (2) The consequences of an arrangement declared to be an impermissible avoidance arrangement as referred to in sub-section (1) shall include but shall not be limited to the following:- (a) disregarding, combining or recharacterising any step in, or a part or whole of, the impermissible avoidance arrangement; (b) treati....