Impermissible avoidance arrangement: Commissioner records satisfaction and refers case to Approving Panel for GAAR assessment action. Form No. 3CEI records the Commissioner's satisfaction before referring a matter to the Approving Panel under section 144BA, requiring assessee identification, assessment years subject to GAAR, dates of procedural communications, a factual matrix, assessment-year-wise tax benefit details, the basis for computing benefits, and whether tax benefit was the main purpose. The form requires identification of which indicia of impermissible avoidance are satisfied (non arm's length rights, misuse/abuse of the Act, lack of commercial substance, or non ordinary means), a summary of the assessee's hearing response, detailed reasons for concluding impermissible avoidance, likely tax consequences, and the last date for completion of assessment or reassessment.