Part DCA - Safe Harbour Rules for income referred to in clause (i) of sub-section (1) of section 9 chargeable to tax under the head (From Rule 10TI to Rule 10TIC)
General anti avoidance rule notice procedure requires prior objections, detailed reasons, and prescribed forms before reference. The procedure under section 144BA requires the Assessing Officer to issue a written notice to the assessee before making a reference to the Commissioner, seeking objections to the applicability of Chapter X-A. The notice must specify the arrangement, the tax benefit, the reasons for treating the main purpose as obtaining tax benefit, the reasons for satisfaction of section 96(1) conditions, and the supporting documents and evidence. The reference is to be made in Form No. 3CEG, and the Commissioner must record satisfaction in Form No. 3CEI before reference to the Approving Panel.
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General anti avoidance rule notice procedure requires prior objections, detailed reasons, and prescribed forms before reference.
The procedure under section 144BA requires the Assessing Officer to issue a written notice to the assessee before making a reference to the Commissioner, seeking objections to the applicability of Chapter X-A. The notice must specify the arrangement, the tax benefit, the reasons for treating the main purpose as obtaining tax benefit, the reasons for satisfaction of section 96(1) conditions, and the supporting documents and evidence. The reference is to be made in Form No. 3CEG, and the Commissioner must record satisfaction in Form No. 3CEI before reference to the Approving Panel.
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