Form for making the reference to the Commissioner by the Assessing Officer u/s 144BA(1)

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.... 5. Assessment year(s) in respect of which the proceedings under section 144BA are proposed to be invoked : (a) Assessment years for which proceedings are pending (b) Other assessment years proposed to be covered 6. Factual matrix of the arrangement entered into by the assessee including details of other parties. 7. Details of tax benefit (assessment year-wise) a rising under the arrangeme....

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....med to lack commercial substance under section 97, in whole or in part; or (d) is entered into, or carried out, by means, or in manner, which are not ordinarily employed for bona-fide purposes. 13. Brief reasons for seeking declaration of the arrangement as impermissible avoidance arrangement. 14. Consequences in relation to tax likely to arise if the arrangement is declared as an imperm....