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of <h1>Section 274: Hierarchical process for referring suspected tax avoidance to Approving Panel, notice, hearings, investigation, binding multi-year directions</h1> Section 274 establishes a hierarchical procedure empowering an Assessing Officer to refer suspected impermissible avoidance arrangements to a Principal Commissioner/Commissioner and, if unresolved, to an Approving Panel which can declare arrangements impermissible and determine Chapter XI consequences; it mandates reasons-based notice, a hearing opportunity, investigatory powers (including international information requests), specified time-limits with certain exclusions, and binding, non-appealable directions applicable to multiple years. The Approving Panel's composition and rulemaking support are prescribed. Differences between the enacted provision and the originally introduced clause are limited to minor drafting and stylistic variations without material impact on rights, timelines, or operational mechanics.
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