Impermissible avoidance arrangement: new referral and approval mechanism requires Commissioner and Approving Panel review before invoking Chapter X A consequences. A new procedure permits an Assessing Officer to refer arrangements suspected to be impermissible avoidance arrangements to the Commissioner, who must notify the assessee, allow objections and hearing, and either direct invocation of Chapter X-A or refer unresolved matters to an Approving Panel. The Approving Panel, constituted by the Board, may require further inquiry, call records, and issue binding directions including specification of relevant previous years; assessments reflecting Chapter X-A consequences require prior Commissioner approval where such directions have been issued.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Impermissible avoidance arrangement: new referral and approval mechanism requires Commissioner and Approving Panel review before invoking Chapter X A consequences.
A new procedure permits an Assessing Officer to refer arrangements suspected to be impermissible avoidance arrangements to the Commissioner, who must notify the assessee, allow objections and hearing, and either direct invocation of Chapter X-A or refer unresolved matters to an Approving Panel. The Approving Panel, constituted by the Board, may require further inquiry, call records, and issue binding directions including specification of relevant previous years; assessments reflecting Chapter X-A consequences require prior Commissioner approval where such directions have been issued.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
