TMI BlogInsertion of new section 144BA.X X X X Extracts X X X X X X X X Extracts X X X X ..... at any stage of the assessment or reassessment proceedings before him having regard to the material and evidence available, considers that it is necessary to declare an arrangement as an impermissible avoidance arrangement and to determine the consequence of such an arrangement within the meaning of Chapter X-A, then, he may make a reference to the Commissioner in this regard. (2) The Co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , after hearing the assessee in the matter, is not satisfied by the explanation of the assessee, then, he shall make a reference in the matter to the Approving Panel for the purpose of declaration of the arrangement as an impermissible avoidance arrangement. (5) If the Commissioner is satisfied, after having heard the assessee that the provisions of Chapter X-A are not to be invoked, he ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the case may be. (8) The Approving Panel may, before issuing any direction under sub-section (6), (i) if it is of the opinion that any further inquiry in the matter is necessary, direct the Commissioner to make such further inquiry or cause to make such further inquiry to be made by any other income-tax authority and furnish a report containing the results of such inq ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion (6) specifies that declaration of the arrangement as impermissible avoidance arrangement is applicable for any previous year to which the proceeding referred to in sub-section (1) pertains, then, the Assessing Officer while completing any assessment or reassessment proceedings of the assessment year relevant to such other previous year shall do so in accordance with such directions and the pro ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... isting of not less than three members, being (i) income-tax authorities not below the rank of Commissioner; and (ii) an officer of the Indian Legal Service not below the rank of Joint Secretary to the Government of India. (15) The Board may make rules for the purposes of the efficient functioning of the Approving Panel and expeditious disposal of the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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