96. Impermissible avoidance arrangement .
(1)An impermissible avoidance arrangement means
an arrangement, the main purpose of which is to obtain a tax benefit, and it - (a)creates rights, or obligations, which are not ordinarily created between persons dealing at
arm’s length; (b)results, directly or indirectly, in the misuse, or abuse, of the provisions of this Act; (c)lacks commercial substance or is deemed to lack commercial substance under section 97 , in
whole or in part; or