The Indian authorities proposed the introduction of a General Anti-Avoidance Rule (GAAR) in the Budget for 2012/13 to be effective from 1 April 2013. In furtherance of this, the Central Board of Direct Taxes (CBDT) formed a Committee to provide recommendations on the formulation of guidelines with regard to the application of the GAAR and the recommendations were released on 28 June 2012. The…