Form No. 064 - Form for making reference to the Approving Panel and for recording the satisfaction by the Commissioner before making a reference to the Approving Panel under section 274(4)

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Impermissible avoidance arrangement reference form records Commissioner satisfaction and supporting details before referral to the Approving Panel. Form No. 64 prescribes the format for a Commissioner of Income-tax to record satisfaction before making a reference to the Approving Panel under section 274(4) regarding a proposed impermissible avoidance arrangement. It requires particulars of the assessee, the relevant tax years, notice and hearing details, assessment deadlines, and detailed reasons for the conclusion. Annexures must cover the factual matrix, tax benefit, the main purpose test, statutory conditions indicating impermissibility, the assessee's hearing, and likely tax consequences.

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Impermissible avoidance arrangement reference form records Commissioner satisfaction and supporting details before referral to the Approving Panel.

Form No. 64 prescribes the format for a Commissioner of Income-tax to record satisfaction before making a reference to the Approving Panel under section 274(4) regarding a proposed impermissible avoidance arrangement. It requires particulars of the assessee, the relevant tax years, notice and hearing details, assessment deadlines, and detailed reasons for the conclusion. Annexures must cover the factual matrix, tax benefit, the main purpose test, statutory conditions indicating impermissibility, the assessee's hearing, and likely tax consequences.

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Form No. 064 - Form for making reference to the Approving Panel and for recording the satisfaction by the Commissioner before making a reference to the Approving Panel under section 274(4)

Impermissible avoidance arrangement reference form records Commissioner satisfaction and supporting details before referral to the Approving Panel.

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Form No. 064 - Form for making reference to the Approving Panel and for recording the satisfaction by the Commissioner before making a reference to the Approving Panel under section 274(4)

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Impermissible avoidance arrangement reference form records Commissioner satisfaction and supporting details before referral to the Approving Panel.

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