Explain briefly the provision of General Anti Avoidance Rule ('GAAR') in the following independent cases: (c) Impermissible avoidence agreement is the substance of GAAR. Mention in brief what are the constituents of impe

Section 96 of the income tax Act, 1961 refer to and defines an "Impermissible Avoidance Arrangement" - An impermissible avoidance arrangement means an arrangement, the main purpose of which is to obtain a tax benefit, and: It creates right, or obligation, which are not ordinarily created between person dealing at arm's length; It result, directly or indirectly, in the misuse, or abuse, of the provision of this Act; Lacks commercial substance or is deemed to lack commercial substance under section 97, in whole or part: or is entered into, or carried out, by means, or in a manner, which are not ordinarily employed for bona fide purpose.