Legislative tool curbing aggressive tax planning and abusive tax avoidance Scheme : Clause 183 of the Income Tax Bill, 2025 Vs. Section 101 of the Income-tax Act, 1961
28 April, 2025
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General Anti-Avoidance Rule expanded to permit concurrent or substitutive application, increasing substance-over-form scrutiny. Clause 183 expands the statutory reach of the General Anti-Avoidance Rule (GAAR) by expressly permitting GAAR to apply "in addition to, or in lieu of" any ... Summary
General Anti-Avoidance Rule expanded to permit concurrent or substitutive application, increasing substance-over-form scrutiny.
Clause 183 expands the statutory reach of the General Anti-Avoidance Rule (GAAR) by expressly permitting GAAR to apply "in addition to, or in lieu of" any other basis for determination of tax liability, while maintaining application "as per such guidelines and subject to such conditions, as prescribed." The clause enables authorities to apply a substance-over-form approach, allowing concurrent or exclusive use of GAAR alongside specific anti-avoidance or substantive provisions, and thereby alters the relationship between GAAR and SAARs previously left ambiguous under Section 101.
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