Revised DTC and GAAR

The revised discussion paper on the Direct Tax Code proposes the following safeguards for invoking GAAR provisions:

i) The Central Board of Direct Taxes will issue guidelines to provide for the circumstances under which GAAR may be invoked.

ii) GAAR provisions will be invoked only in respect of an arrangement where tax avoidance is beyond a specified threshold limit.

iii) The forum of Dispute Resolution Panel (DRP) would be available where GAAR provisions are invoked.
 
I had earlier discussed GAAR provisions under the DTC here.