Notice and Forms for reference under section 274

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....ter XI in his case. (2) The notice referred to in sub-rule (1) shall contain the following:- (a) details of the arrangement to which the provisions of Chapter XI are proposed to be applied; (b) the tax benefit arising under the arrangement; (c) the basis and reason for considering that the main purpose of the identified arrangement is to obtain tax benefit; (....

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....sued under section 274(2). (5) The Commissioner, before making a reference to the Approving Panel under section 274(4), shall, - (a) record his satisfaction regarding the applicability of the provisions of Chapter XI in Form No. 64; and (b) seek specific factual report in writing from the International Financial Service Centre Authority, where the assessee is an entity located....