Held, dismissing the petitions that the arrangement was being scrutinized as it was considered devoid of commercial substance in terms of section 97. It was perceived as a deliberate misuse of the provisions of the Act, going beyond the intended use of the law, and manipulating it to one’s advantage. It created extraordinary rights and obligations that seemed to be conducted not in good faith. These unusual rights and obligations were not in line with the general principles of fair dealing, leading to the conclusion that it was an impermissible tax avoidance agreement under section 96. Consequently, the arrangement fell under the purview of Chapter X-A. Given these circumstances, procedures were set in motion to apply the rules and regulations of Chapter X-A to this arrangement. There was clear and convincing evidence to suggest that the entire arrangement was intricately designed with the sole intent of evading tax. The assessee had not been able to provide substantial and persuasive proof to counter this claim. The Revenue had shown that the share transactions were not permissible tax avoidance arrangements. The evidence pointed towards the fact that these transactions did not qualify as permissible under the tax laws. Therefore, the provisions of Chapter X-A were applicable. The notice under section 144BA was valid. Finance Act, 2013 ([2013] 354 ITR (St.) 1)  (AY.2019-20)