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Comparison of section 274 "Reference to Principal Commissioner or Commissioner in certain cases." between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

9 September, 2025

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Section 274 Reference to Principal Commissioner or Commissioner in certain cases.

Income-tax Act, 2025

At a Glance

Clause 274 of Income Tax Bill, 2025 - Old Version sets out a procedure for an Assessing Officer (AO) to refer matters involving potential "impermissible avoidance arrangements" to the Principal Commissioner or Commissioner and, ultimately, to an Approving Panel for declaration and determination of consequences under Chapter XI. It matters because it creates a multi-tiered, internal administrative route for invoking anti-avoidance provisions, affecting taxpayers under assessment or reassessment and income-tax authorities. Effective date or decision date: Not stated in the document.

Background & Scope

Statutory hooks: Clause 274 of the Income Tax Bill, 2025 and cross-reference to Chapter XI and section 159 (international assistance). The clause governs references by the AO to the Principal Commissioner or Commissioner and onward to an Approving Panel for declaration of an arrangement as an "impermissible avoidance arrangement" and determination of its tax consequences. Definitions of "impermissible avoidance arrangement", "Approving Panel", and detailed terms of Chapter XI are Not stated in the document. The provision covers assessment and reassessment proceedings and contemplates directions binding on the assessee and revenue authorities.

Statutory Provision Mode

Text & Scope

Clause 274 permits an AO to make a reference at any stage of assessment/reassessment when, on the basis of available material and evidence, he considers it necessary to (a) declare an arrangement an impermissible avoidance arrangement and (b) determine the consequences under Chapter XI. On receiving a reference, the Principal Commissioner or Commissioner, if of the view that Chapter XI is to be invoked, must issue a reasons-based notice to the assessee and provide an opportunity to be heard within a period not exceeding sixty days. If the assessee fails to object within the specified time, the Principal Commissioner or Commissioner may issue directions to declare the arrangement impermissible. If the assessee objects and the Principal Commissioner or Commissioner remains unsatisfied after hearing, a reference must be made to the Approving Panel. If satisfied that Chapter XI need not be invoked, the Principal Commissioner or Commissioner must record that in writing and communicate to the AO (with copy to the assessee).

The Approving Panel on reference may issue directions as it deems fit for declaration under Chapter XI and specify tax year(s) to which declaration applies. No such direction is to be issued without hearing the assessee and AO where the directions are prejudicial to either interest of the assessee or revenue. The Approving Panel has investigatory powers: it may order further inquiries (including via authorities under agreements referred in section 159), call for records, and require documents from the assessee. Panel decisions are by majority. Directions of the Principal Commissioner/Commissioner or Approving Panel are binding on the assessee and the Principal Commissioner/Commissioner and subordinate income-tax authorities. No appeal lies against Approving Panel directions. The Central Government shall constitute one or more Approving Panels (three members including a Chairperson who is or has been a High Court judge; one member an IRS officer at specified rank; one member an academic/scholar with specified knowledge). Terms, meetings, remuneration and supporting officials are provided for; certain powers of the Board for Advance Rulings u/s 387 apply mutatis mutandis to the Approving Panel, and the Board shall provide officials. The Board may make rules for constitution and functioning of the Panel and disposal of references.

Interpretation

Legislative intent and interpretive principles indicated by the text: The provision aims to institutionalise an internal approval mechanism before invoking Chapter XI anti-avoidance provisions in an assessment/reassessment, ensuring higher-level review (Principal Commissioner/Commissioner and an independent Approving Panel) and procedural safeguards such as notice and hearing. The text emphasises procedural steps (reference, notice with reasons, hearing, and opportunity to make objections), multi-layer scrutiny, and finality by making Approving Panel directions binding and non-appealable. The use of terms such as "as he deems fit" and "issue such directions" indicates discretionary powers vested in the Principal Commissioner/Commissioner and the Panel. The provision also integrates international cooperation (section 159) into inquiries when necessary. Legislative intent beyond these procedural objectives is Not stated in the document.

Exceptions/Provisos

Carve-outs/conditions present in the text include:

  • Opportunity to be heard: No direction under sub-section (6) shall be issued unless opportunity of being heard is given to the assessee and the AO where directions are prejudicial to interests (sub-section (7)).
  • Time-limits for Panel: Approving Panel to issue directions within six months from end of month in which reference received, subject to specified exclusions (sub-sections (13)-(15)).
  • Exclusions to time computation: periods where Panel directs inquiries under agreements referred in section 159 (limited to one year or duration of information retrieval) and periods of judicial stay (sub-section (14)).
  • Binding effect and finality: Directions of the Panel are binding and not appealable (sub-sections (16) and (17)).

Illustrations

  • Example 1: An AO detects a complex arrangement in a taxpayer's return that appears to shift profits to a low-tax jurisdiction. The AO, considering available documents, refers the matter to the Principal Commissioner under sub-section (1) to seek declaration as an impermissible avoidance arrangement and determination under Chapter XI. (Consistent with text.)
  • Example 2: The Principal Commissioner issues a reasoned notice and the assessee objects within 30 days, but the explanation is unsatisfactory; the Principal Commissioner refers to the Approving Panel under sub-section (4). The Panel may direct further inquiries u/s 159 and thereafter issue binding directions applicable to multiple tax years as specified. (Consistent with text.)
  • Example 3: The Approving Panel, after hearing both parties, specifies that the declaration applies to the tax year under assessment and two prior years; AO must apply these directions while completing assessments for those years without seeking fresh directions (consistent with sub-section (11)).

Interplay

Interactions with other provisions mentioned: explicit reference to Chapter XI for substantive anti-avoidance consequences and to section 159 for obtaining information through competent authorities under international agreements. The Approving Panel may exercise certain powers of the Board for Advance Rulings u/s 387 mutatis mutandis. Specific rules, forms or subordinate instruments that may be made under this clause are Not stated in the document beyond a general power for the Board to make rules for constitution and functioning of the Panel.

Practical Implications

  • Compliance and risk areas: Taxpayers subject to assessment/reassessment face a structured process that could result in binding, non-appealable determinations that may span multiple tax years. There is a heightened procedural risk where an AO refers matters upwards; once the Approving Panel issues directions, those are binding and not subject to appeal under the Act. The text makes clear that invoking Chapter XI requires higher-level concurrence, concentrating decision-making at senior and quasi-judicial levels.
  • Record-keeping/evidence points: The provision contemplates inquiries, requests for documents, and international information exchange u/s 159; taxpayers should therefore maintain contemporaneous records and be prepared to respond to reasoned notices from the Principal Commissioner/Commissioner and to directions from the Approving Panel. The text itself requires the Principal Commissioner/Commissioner to set out reasons and basis in notices, indicating the centrality of documentary evidence and reasoned explanations.

Key Takeaways

  • Clause 274 creates a hierarchical review and approval mechanism for invoking Chapter XI anti-avoidance powers through references from AO to Principal Commissioner/Commissioner and to an Approving Panel.
  • Procedural safeguards include a reasons-based notice to the assessee, opportunity to be heard (within 60 days), and a requirement to refer to the Approving Panel when explanations are unsatisfactory.
  • The Approving Panel has investigatory powers, can specify tax years of applicability, and its directions are binding and not appealable under the Act.
  • Time-limits for Panel decisions are prescribed (six months with specified exclusions), but the text allows extensions through exclusions and a minimum remaining period of sixty days.
  • Composition of the Approving Panel combines judicial, senior revenue, and academic expertise; the Board will provide support and may make rules for functioning.
  • The clause integrates international cooperation (section 159) and confers certain powers analogous to the Board for Advance Rulings (section 387) on the Approving Panel.
  • Effective date, definitions of key terms (e.g., "impermissible avoidance arrangement"), and appeal or judicial review pathways beyond the Act's internal bar are Not stated in the document.

Differences between Document 1 (Section 274 of Income-tax Act, 2025) and Document 2 (Clause 274 of Income Tax Bill, 2025 - Old Version) and Practical Impact

Provision/Clause Difference in Text Practical Impact

Terminology in notices (sub-section (3))

Doc1 uses the phrase "within the time specified in such notice issued under sub-section (2)"; Doc2 says "within the time specified in the notice issued under sub-section (2)".

Purely stylistic; no substantive change in meaning or effect.

Reference to other tax years (sub-section (11)(b))

Doc1: "for such other tax year." Doc2: "for the relevant tax year."

No material change: both indicate no fresh direction required for application to other years; wording difference does not alter scope.

Computation exclusion relating to first direction (sub-section (14)(a))

Doc1: "commencing from the date on which the Approving Panel first directs the Principal Commissioner or Commissioner for getting the inquiries conducted..." Doc2: "commencing from the date on which the first direction is issued by the Approving Panel to the Principal Commissioner or Commissioner for getting the inquiries conducted..."

Stylistic drafting variation; no practical effect on timing or process.

Remuneration wording for Panel members (sub-section (21))

Doc1: "paid such remuneration as may be prescribed." Doc2: "shall be paid such remuneration as prescribed."

Minor drafting variance; both envisage remuneration prescribed by rules-no substantive difference in authority to prescribe or pay remuneration.

Minor phrasing about satisfaction after hearing (sub-section (4))

Doc1: "not satisfied with the explanation of the assessee." Doc2: "not satisfied by the explanation of the assessee."

Purely linguistic; no practical impact.

  • Overall practical impact of the differences: the variations between the two texts are limited to minor drafting and stylistic changes with no material effect on substantive rights, duties, timelines or the operational mechanics of the referral, inquiry and decision-making process as set out in Clause/Section 274.

Full Text:

Section 274 Reference to Principal Commissioner or Commissioner in certain cases.

Topics

Acts Income Tax
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