Comptroller of Income Tax v AQQ

Section 33 of the Income Tax Act is applied through a 'scheme and purpose' approach: an arrangement falls within s 33(1) if its purpose or effect is to alter the incidence of, relieve from, or reduce a liability to tax, but it is saved by the s 33(3)(b) exception where it was carried out for bona fide commercial reasons and did not have tax avoidance as one of its main purposes.