GAAR reference procedure requires notice, hearing, Approving Panel review, binding directions, and coordinated assessment across specified tax years

Section 274 establishes a GAAR procedure for identifying Impermissible Avoidance Arrangements and determining Chapter XI tax consequences. The Assessing Officer may refer a matter to the Principal Commissioner or Commissioner after giving the assessee notice of the arrangement, tax benefit, reasons, statutory grounds, and supporting evidence. The Commissioner must provide notice and a hearing, and unresolved objections require reference to the Approving Panel. The Panel may investigate, hear the assessee and Assessing Officer, specify applicable tax years, and issue binding directions that cannot be appealed. The Assessing Officer must follow those directions, and prior approval is required before passing an assessment or reassessment order involving Chapter XI consequences.

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