Insertion of new section 144BA.

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....X-A, then, he may make a reference to the Commissioner in this regard.       (2) The Commissioner shall, on receipt of a reference under sub-section (1), if he is of the opinion that the provisions of Chapter X-A are required to be invoked, issue a notice to the assessee, setting out the reasons and basis of such an opinion, for submitting objections, if any, and providing an opportunity of being heard to the assessee within such period, not exceeding sixty days, as may be specified in the notice.       (3) If the assessee does not furnish any objection to the notice within the time specified in the notice issued under sub-section (2), the Commissioner shall issue such directions as it....

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....e.       (8) The Approving Panel may, before issuing any direction under sub-section (6),-            (i) if it is of the opinion that any further inquiry in the matter is necessary, direct the Commissioner to make such further inquiry or cause to make such further inquiry to be made by any other income-tax authority and furnish a report containing the results of such inquiry to it; or            (ii) call for and examine such records related to the matter as it deems fit; or            (iii) require the assessee to furnish such document and evidence as it ....

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....ub-section (6) or sub-section (3) declaring the arrangement as impermissible avoidance arrangement.       (13) No direction under sub-section (6) shall be issued after a period of six months from the end of the month in which the reference under sub-section (4) was received by the Approving Panel.       (14) The Board shall, for the purposes of this section, constitute an Approving Panel consisting of not less than three members being the income tax authorities of the rank of Commissioner and above.       (15) The Board may make rules for the purposes of the efficient functioning of the Approving Panel and expeditious disposal of the references received unde....

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....resaid new section provides that if, after hearing the assessee, the Commissioner is satisfied that it is not a fit case for invoking provisions of Chapter X-A, he may pass an order in writing with copy to the Assessing Officer and the assessee. The proposed sub-section (6) of the aforesaid new section provides that Approving Panel on receipt of reference from Commissioner shall issue such directions as it deems fit in respect of declaration of an arrangement as an impermissible avoidance arrangement. It may also provide in direction the previous year or years to which such direction shall apply. The proposed sub-section (7) of the aforesaid new section provides that a direction prejudicial either to assessee or revenue shall not be i....