GAAR main purpose test targets arrangements primarily motivated by tax benefit, with procedural safeguards for invocation.
Clause 179 defines an impermissible avoidance arrangement under GAAR as one whose main purpose is obtaining a tax benefit and which meets at least one of four tainting conditions: arm's length departure, misuse or abuse of law, lack of commercial substance, or non bona fide means; it creates a rebuttable presumption placing the burden on the taxpayer for impugned steps and is operationalized through Rule 10UB's pre reference notice, Commissioner review, and Approving Panel safeguards.