Impermissible avoidance arrangement reference under section 144BA triggers AO transmission of prescribed information for Commissioner evaluation. Form 3CEG requires an Assessing Officer referring an arrangement to the Commissioner under section 144BA(1) to provide assessee identification, assessment years, factual matrix, year-wise tax benefits to all parties, computation basis, and whether tax benefit was the main purpose. The AO must state if a procedural notice was served and summarize the assessee's reply, identify which indicia of impermissible avoidance apply (arm's length deviations, misuse/abuse, lack of commercial substance, or atypical means), give reasons for seeking a declaration, outline likely tax consequences, and state the last date for completing assessment or reassessment.
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 reference under section 144BA triggers AO transmission of prescribed information for Commissioner evaluation.
Form 3CEG requires an Assessing Officer referring an arrangement to the Commissioner under section 144BA(1) to provide assessee identification, assessment years, factual matrix, year-wise tax benefits to all parties, computation basis, and whether tax benefit was the main purpose. The AO must state if a procedural notice was served and summarize the assessee's reply, identify which indicia of impermissible avoidance apply (arm's length deviations, misuse/abuse, lack of commercial substance, or atypical means), give reasons for seeking a declaration, outline likely tax consequences, and state the last date for completing assessment or reassessment.
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