Arrangement to lack commercial substance [ Section 97(1)(d) ] - Income Tax - Ready Reckoner - Income Tax

Another alternate condition of an impermissible avoidance arrangement is that the arrangement lacks commercial or is deemed to lack commercial substances in whole or in part. An arrangement shall be deemed to lack commercial substance, if- (d) it does not have a significant effect upon the business risks or net cash flows of any party to the arrangement apart from any effect attributable to the tax benefit that would be obtained (but for the provisions of this Chapter). [ Section 97(1)(d) ]