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of <h1>Chapter X-A: Commissioner referral, hearing and Approving Panel can direct declarations; panel decisions final and binding</h1> If an assessing officer considers an arrangement may be an impermissible avoidance arrangement under Chapter X-A, he may refer it to the Commissioner. The Commissioner must notify the assessee, allow objections and hearing within a specified period; absent objections he may direct declaration. If unconvinced after hearing, the Commissioner refers the matter to an Approving Panel, which after hearing may direct declaration and specify applicable prior year(s). Panel directions are binding, final and ordinarily issued within six months (with limited exclusions). Assessments invoking Chapter X-A consequences require prior Commissioner approval. The Central Government constitutes Panels, prescribes membership, term, powers and rules; the Panel has AAR-like powers.
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