(4)For the removal of doubts, it is hereby clarified that the following may be relevant but shall not be sufficient for determining whether an arrangement lacks commercial substance or not, namely:-(i)the period or time for which the arrangement (including operations therein) exists;(ii)the fact of payment of taxes, directly or indirectly, under the arrangement;(iii)the fact that an exit route (including transfer of any activity or business or operations) is provided by die arrangement.
