Ketan Dalal, joint leader, Tax and Regulatory Services, PwC India, talks about two specific things with regards to the GAAR final rules. First, he lists the positive part: GAAR will be applied only if tax avoidance is the 'main purpose' rather than 'one of the purposes'. His second observation: the nearly absolute power given to the tax panel while deciding applicability of GAAR could be tricky in case of disputes.