VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — sections 100 and 101: Chapter X-A applies in addition to or in lieu of any other basis, and only in accordance with prescribed guidelines
CBDT Circulars & InstructionsCuts both wayss.100s.101s.95s.96s.98s.144BARule 10URule 10UARule 10UBRule 10UC

Statutory position — sections 100 and 101: Chapter X-A applies in addition to or in lieu of any other basis, and only in accordance with prescribed guidelines

Can the department run GAAR and a specific anti-avoidance provision on the same transaction, and is there anything that limits how GAAR is applied?

Can the department run GAAR and a specific anti-avoidance provision on the same transaction, and is there anything that limits how GAAR is applied?

Section 100 provides that the provisions of Chapter X-A shall apply in addition to, or in lieu of, any other basis for determination of tax liability — so GAAR is not an alternative of last resort and can be invoked alongside, or instead of, a specific charging or anti-avoidance provision. Section 101 provides that the Chapter shall be applied in accordance with such guidelines and subject to such conditions as may be prescribed, and it is under that section that rules 10U to 10UC are made.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2018-04-01, reported as Income-tax Act, 1961, sections 100 and 101. It bears on section 100, section 101, section 95, section 96, section 98, section 144BA, section Rule 10U, section Rule 10UA, section Rule 10UB, section Rule 10UC of the Income Tax Act 1961, in Assessment & Scrutiny and How Tax Law Is Read matters.

Still good law. This is the statutory text, not a decision about it. Both sections were read on departmental pages carrying a 'Year: 2025' stamp and neither prints an amendment footnote. Later treatment was NOT fully checked: the only decision located on this pass that argues section 100 in this way is the Mumbai Tribunal order in ITA No.2503/Mum/2026 dated 31 August 2026, which expressly refrained from deciding the wider proposition; no appellate treatment of that order was checked.

Why it matters

Section 100 is the answer the department gives to the commonest defence to a GAAR notice — that the transaction is already dealt with by a specific anti-avoidance rule in Chapter X, so the general rule cannot apply. On the plain words it is a poor defence: the Chapter applies 'in addition to' another basis as well as 'in lieu of' it. But section 100 cuts both ways. Because it is expressed as a rule about the relationship between bases of determination, it also means that a finding under Chapter X-A does not exhaust the department's other provisions and, equally, that the failure of a Chapter X-A case does not by itself establish that another provision is unavailable — a point that has now been argued both ways before the Tribunal. Section 101 is the smaller section but it is the one that makes the rules mandatory rather than administrative: 'shall be applied in accordance with such guidelines and subject to such conditions, as may be prescribed' means the three-crore threshold in rule 10U(1)(a), the grandfathering in rule 10U(1)(d), the pre-reference notice in rule 10UB(1) and the time limits in rule 10UC are conditions on the application of the Chapter, not internal departmental instructions. A GAAR proceeding that does not comply with them is not merely irregular.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

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Related

Other authorities on the same sections.