For the purposes of this Chapter,—

(1) “tax benefit” shall include the following, namely:—

(a) directly or indirectly avoiding or reducing the liability of income tax;

(b) directly or indirectly relieving a person from liability to pay income-tax or from a potential or prospective liability to future income-tax;

(c) directly or indirectly, avoiding, deferring or reducing any income tax liability, or any potential or prospective liability to future income-tax;

(d) delay in payment of income-tax;

(e) avoidance of the obligation to deduct or collect tax at source and deposit such tax in the Government treasury;

(2) “arrangement” means any consent, agreement, scheme or consensus enforceable or not enforceable and all acts and transactions through which it is executed;

(3) “abuse of tax arrangement” means any arrangement, whether executed by the person affected by the arrangement or any other person—

(a) which, in the absence of this section, directly or indirectly creates one or more tax benefits unless the arrangement is reasonably adopted or created for a bona-fide purpose other than the purpose of obtaining a tax benefit; or

(b) which, is a part of a multiple arrangement and the multiple arrangement, in the absence of this section, creates directly or indirectly 1 (one) or more tax benefits unless the multiple arrangement are reasonably adopted or created for any purpose other than the purpose of obtaining tax advantage.