An avoidance arrangement is an impermissible avoidance arrangement if its sole or main purpose was to obtain a tax benefit and—
| (a) | in the context of business— |
| (i) | it was entered into or carried out by means or in a manner which would not normally be employed for bona fide business purposes, other than obtaining a tax benefit; or |
| (ii) | it lacks commercial substance, in whole or in part, taking into account the provisions of section 80C; |
| (b) | in a context other than business, it was entered into or carried out by means or in a manner which would not normally be employed for a bona fide purpose, other than obtaining a tax benefit; or |
(c) in any context—
| (i) | it has created rights or obligations that would not normally be created between persons dealing at arm’s length; or |
| (ii) | it would result directly or indirectly in the misuse or abuse of the provisions of this Act (including the provisions of this Part). |
