(a) In this section -
'relevant transaction' means any scheme, arrangement or understanding under which a person becomes entitled to receive a capital sum and the consideration given for the entitlement to receive the sum consists wholly or mainly of the direct or indirect transfer to another person of a right to receive rent which, in the absence of the scheme, arrangement or understanding, could reasonably have been expected to accrue to the first-mentioned person or to a person connected with that person;
'rent' includes any sum which -
(i) is chargeable to tax under Case V of Schedule D, or
(ii) would be so chargeable if the source of the sum were in the State.
(b) For the purposes of this section, a scheme, arrangement or understanding under which a person grants a lease in connection with which -
(i) the person is entitled to a capital sum,
(ii) rent is payable to another person, and
(iii) the consideration given for the entitlement to receive the capital sum consists wholly
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