Section 96 → Section 195
Impermissible avoidance arrangement
Quick Answer
Section 96 of the Income Tax Act, 1961 (Impermissible avoidance arrangement) corresponds to Section 195 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective 1st April 2026. Status: Retained.
Sec 96
Provision Summary
Defines an impermissible arrangement as one whose main purpose is to obtain a tax benefit AND it creates abnormal rights, misuses the law, lacks commercial substance, or is not bona fide.
Sec 195
Provision Summary
Retained verbatim. The 'Main Purpose' test is central to invoking GAAR.
Key Changes & Highlights
- AI algorithms analyze complex M&A and demerger documents to flag potential GAAR violations for the review panel.
Related Sections
Frequently Asked Questions
What does Section 96 of the Income Tax Act 1961 deal with?
Section 96 (Impermissible avoidance arrangement) Defines an impermissible arrangement as one whose main purpose is to obtain a tax benefit AND it creates abnormal rights, misuses the law, lacks commercial substance, or is not bona fide.
What is the new section number for Section 96 under the Direct Tax Code 2025?
Section 96 of the ITA 1961 maps to Section 195 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective from 1st April 2026.
What is the status of Section 96 under the new tax code?
Section 96 is marked as "Retained" with status "Active". Impact: High - Sets the legal boundary for aggressive tax planning.
What are the key changes to Section 96 under DTC 2025?
AI algorithms analyze complex M&A and demerger documents to flag potential GAAR violations for the review panel.
Disclaimer: This page is for educational and reference purposes only. Section mappings are based on publicly available drafts and circulars. Always consult a qualified Chartered Accountant before filing or making compliance decisions under the Direct Tax Code 2025.
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