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of <h1>Commissioner Reviews Tax Case Referrals Under Section 144BA(4) for Potential Impermissible Avoidance Arrangements.</h1> This form is used by the Commissioner to record satisfaction before referring a case to the Approving Panel under section 144BA(4) of the Income Tax Act. It includes details such as the assessee's name, address, identification number, status, and residential status. The form outlines the assessment years involved, dates of relevant notices and submissions, and the factual matrix of the arrangement under scrutiny. It assesses whether the arrangement primarily aims to obtain tax benefits and if it meets certain conditions like creating non-arm's length obligations or lacking commercial substance. It also records the assessee's opportunity to respond and the potential tax consequences if deemed an impermissible avoidance arrangement.
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