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International TaxArticle·25 October 2025

High Table Occupied by GAAR and SAAR

By J the App

Executive Summary

Decoding India’s evolving anti-avoidance architecture — where SAAR’s precision meets GAAR’s principle. J the App by JustIDT snapshot on Section 94 and Chapter X-A examines how this twin Provisions redefine tax integrity, substance tests, and transaction design. The paper also explores how GAAR’s discretionary reach and SAAR’s statutory clarity now shape India’s tax landscape and risk management frameworks committed to advancing evidence-based, substance-driven tax strategy in a post-BEPS world. And absolute reliance on TRCs and Treaties alone does not work anymore.

SAAR (Section 94) and GAAR — India’s Dual Anti-Avoidance Framework

Executive Summary

India’s anti-avoidance regime operates th...

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