Origin, 2017 enactment, threshold rules, impermissible avoidance arrangements, consequences, safeguards.
Chapter 1 — GAAR: Legislative Architecture
Origin, 2017 enactment, threshold rules, impermissible avoidance arrangements, consequences, safeguards.
Chapter 2 — Judicial Doctrine: McDowell to Vodafone
Chapter 3 — Commercial Substance & Business Intent
How to defend genuine arrangements. Tests courts apply. What "bona fide" actually means in Indian tax litigation.
Chapter 4 — Treaty Abuse & International Avoidance
Treaty shopping, LOB clauses, OECD BEPS alignment, Mauritius/Singapore route cases, multilateral instrument (MLI).
+ Annexures:
Original ITAT/SC extracts · Graphic illustrations of circular schemes · Round-tripping diagrams · Comparative table: India vs UK/US/Canada doctrines
5 things reader walks away with:
Clear doctrinal map — from Westminster to GAAR. No gaps.
Practitioner vocabulary — blinkers test, look-through, pre-ordained transaction. Use in court, not just exams.
Pattern recognition — spot sham arrangements, circular devices, round-tripping structures before they become problems.
Global context — Indian law doesn't exist in a vacuum. UK Ramsay, US economic substance, Canadian GAAR — all here.
Exam + litigation ready — structured for IRS aspirants and for senior counsel preparing appeals.
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