In Comptroller of Income Tax v. AQQ [2014] SGCA 15 (AQQ), a case which involves the interpretation and application of the general anti-avoidance rule in section 33 of Singapore’s Income Tax Act, the Singapore Court of Appeal ruled that the statutory exception provided in section 33(3)(b) is not the only protection afforded to a taxpayer from the potentially over-inclusive reach that would follow from a literal interpretation of the threshold limbs in section 33(1).