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of <h1>Procedure under Chapter XI for declaring arrangements as impermissible avoidance, referrals to Principal Commissioner and Approving Panel</h1> An Assessing Officer may refer a matter to the Principal Commissioner/Commissioner where material suggests an arrangement may be an impermissible avoidance arrangement under Chapter XI. The Principal Commissioner/Commissioner must notify the assessee, allow up to 60 days for objections and hearing, and may either direct declaration as impermissible or refer contested cases to an Approving Panel. The Approving Panel may direct declaration and specify applicable tax years, conduct or require inquiries, and must give affected parties a hearing; its directions are binding and not appealable. The Central Government constitutionally appoints three-member panels (including a retired High Court judge), prescribes terms, powers and administrative support.
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