Description

A Veritable Section-Wise Commentary on the General Anti-Avoidance Rules (GAAR) as re-enacted by the Finance Act, 2013, incorporating Parthasarathi Shome Report and also a study of Specific Avoidance Rules under the Income- tax Act and under a tax treaty and a study of judge-made rules relating to avoidance of tax such as - economic substance; sham transaction; business purpose; step transaction; and substance —over form transactions, explained with help of decisions of the courts from India, Canada, South Africa, Australia, the UK and the USA. The book consists of 16 Chapters dealing with :
Various concepts surrounding the concept of tax avoidance and tax evasion, the concept of GAAR, background and general principles, their overriding effect;
Applicability of the GAAR;
Impermissible avoidance arrangement;
Arrangement lacking commercial substance;
Consequences of impermissible avoidance arrangement;
Treatment of connected and accommodating party;
Framing of guidelines by the Government;
Explaining various expressions as defined in the Act;
Procedure and reference to the Commissioner/Principal Commissioner.