General Anti Avoidance Rule enhancements provide thresholds and safeguards to limit abusive tax arrangements and ensure procedural protections.
The paper replaces asset based MAT with a book profit MAT to mitigate hardship, adopts an EET savings approach with EEE retention for certain public instruments, abandons mandatory nationwide retirement accounts while preserving employer contribution exemptions, rejects presumptive notional rent for recent property acquisitions, recalibrates capital gains (with transition relief and FII treatment), institutes a registration based taxed surplus regime for NPOs with limited carry forward, clarifies SEZ grandfathering, defines residence by place of effective management with CFC rules, proposes treaty interaction favouring taxpayer benefit, contemplates a calibrated wealth tax on unproductive assets, and refines GAAR with triggers, thresholds and procedural safeguards. (AI Summary)