Explain in brief whether in the following independent cases, will GAAR provisions apply. (iii) Aman Ltd. is an Indian Company. It sets up a unit in a SEZ for manufacturing of Cement. It claims 100% deductions of profits

There is an arrangement of setting up a unit in SEZ which results in tax benefits. However, this is clearly a case of Tax mitigation wherein the assessee is taking advantage of a benefit offered to him vide adherence to the conditions so imposed, and the consequences that emanate from it, that is setting up a business in a SEZ area. Hence, Revenue would not ideally invoke GAAR in this situation.