GAAR Invocation Requires Concrete Evidence — Mere Timing of Transactions Cannot Trigger Anti-Avoidance

Requirement of Transaction-Specific Benchmarking – No Blanket Validation Across Inter-Company Dealings

Stay of demand must consider merits and hardship, not rigid 20% pre-deposit

Substance Check for PE Determination

Taxability of Employee Stock Purchase | Scheme (‘ESPS’) in the hands of Employees