What is the main purpose of 'Impermissible Avoidance Agreement'? Also state the elements or tests need to be satisfied to consider an agreement as Impermissible Avoidance Agreement.

The main purpose or intent of the 'Impermissible Avoidance Agreement' as mentioned in the provisions related to General Anti Avoidance Rules (GAAR) under Income Tax Act is to obtain Tax benefit. The arrangement should have one or more below mentioned specified elements: The arrangement creates rights or obligations which are not ordinarily created between persons dealing at arm's length The arrangement results, directly or indirectly, in the misuse or abuse of the provisions of the Act The arrangement lacks commercial substance or is deemed to lack commercial substance under section 97 of the Act, in whole or in part The arrangement is entered into or carried out by means or in a manner which are not ordinarily employed for bona fide purposes.