Section 178 — Applicability of General Anti-Avoidance Rule

(1) Irrespective of anything contained in this Act, an arrangement entered
into by an assessee may be declared to be an impermissible avoidance ar -
rangement and the consequence in relation to tax arising from it may be determined
subject to the provisions of this Chapter.
(2) The provisions of this Chapter may be applied to any step in, or a part of, the
arrangement as they are applicable to the arrangement.