In this section and sections 161, 162, 163, 165, 171 and 172, unless the context otherwise requires,—(a) “arm’s length price” means a price which is applied or proposed to be applied in a transaction between persons other than associated enterprises, in uncontrolled conditions;(b) “enterprise” means a person (including a permanent establishment of such person) who […]

(1) Where there is a transfer of assets before and after the commencement of this Act, and by virtue or in consequence of it,––(a) either alone; or(b) in conjunction with associated operations, any income becomes payable to a non-resident, the provisions of this section shall apply.(2) If any person (“first mentioned person”), by means of

(1) Where the owner of any securities (hereinafter referred to as “the owner”) sells or transfers such securities and buys back or reacquires them or buys or acquires any similar securities, any interest that becomes payable in respect ofsuch securities,––(a) is receivable by a person other than the owner, shall be deemed, for all purposes

(1) The Central Government may, by notification specify any country or territory outside India, as a notified jurisdictional area, having regard to the lack of effective exchange of information with such jurisdiction.(2) Irrespective of anything contrary in this Act, if an assessee enters into a transaction where one of the parties to the transaction is

(1) Irrespective of anything contrary in this Act, any expenditure by way of interest or similar payment in respect of excess interest, as specified in sub-section (4), shall not be deductible in computation of income chargeable under the head “Profits and gains of business or profession”, if,—(a) it is paid or payable by an Indian

(1) Irrespective of anything contained in this Act, an arrangement entered into by an assessee may be declared to be an impermissible avoidance arrangement and the consequence in relation to tax arising from it may be determined subject to the provisions of this Chapter.(2) The provisions of this Chapter may be applied to any step

(1) An impermissible avoidance arrangement means an arrangement, the main purpose of which is to obtain a tax benefit, and it—(a) creates rights, or obligations, which are not ordinarily created between persons dealing at arm’s length;(b) results, directly or indirectly, in the misuse, or abuse, of the provisions of this Act;(c) lacks commercial substance or

(1) An arrangement shall be deemed to lack commercial substance, if––(a) the substance or effect of the arrangement as a whole, is inconsistent with, or differs significantly from, the form of its individual steps or a part; or(b) it involves or includes—(i) round trip financing; or(ii) an accommodating party; or(iii) elements that have effect of

(1) If an arrangement is declared to be an impermissible avoidance arrangement, then, the consequences, in relation to tax, of the arrangement, including denial of tax benefit or a benefit under a tax treaty, shall be determined, in the manner as deemed appropriate.(2) The consequences of an arrangement declared to be an impermissible avoidance arrangement

In this Chapter, in determining whether a tax benefit exists,—(a) the parties who are connected persons in relation to each other may be treated as one and the same person;(b) any accommodating party may be disregarded;(c) the accommodating party and any other party may be treated as one and the same person;(d) the arrangement may