(5)The provisions of this section shall not apply if the first mentioned person in sub-section (2) or (3) shows to the satisfaction of the Assessing Officer that—(a)neither the transfer nor any associated operation had for its purpose or for one of its purposes the avoidance of liability to taxation; or(b)the transfer and all associated operations were bona fide commercial transactions and were not designed for the purpose of avoiding liability to taxation.
