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Case lawCBDT Circulars & Instructions › Statutory position — the GAAR procedure: section 144BA, Rules 10UB and 10UC, and the Approving Panel whose direction binds both sides
CBDT Circulars & InstructionsCuts both wayss.144BAs.144BA(1)s.144BA(2)s.144BA(4)s.144BA(6)s.144BA(11)s.144BA(12)s.144BA(13)s.144BA(14)s.95s.96Rule 10UBRule 10UC

Statutory position — the GAAR procedure: section 144BA, Rules 10UB and 10UC, and the Approving Panel whose direction binds both sides

My client has received a notice under Chapter X-A saying his arrangement may be an impermissible avoidance arrangement. What is the procedure from here, who actually decides, and can I appeal the decision?

My client has received a notice under Chapter X-A saying his arrangement may be an impermissible avoidance arrangement. What is the procedure from here, who actually decides, and can I appeal the decision?

GAAR cannot be applied by the Assessing Officer on his own. He must refer the matter to the Principal Commissioner or Commissioner under s.144BA(1) in Form No. 3CEG after first putting a written notice to the assessee under Rule 10UB(1); the Principal Commissioner then issues his own notice under s.144BA(2) giving the assessee up to sixty days to object and a hearing, and either drops the matter in Form No. 3CEH or refers it to the Approving Panel in Form No. 3CEI. The Approving Panel's direction under s.144BA(6) is binding on the assessee and on the Commissioner and his subordinates, and s.144BA(14) bars any appeal under the Act against that direction — the only route against it is a writ.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2018-04-01, reported as Income-tax Act, 1961, section 144BA; Income-tax Rules, 1962, rules 10UB and 10UC. It bears on section 144BA, section 144BA(1), section 144BA(2), section 144BA(4), section 144BA(6), section 144BA(11), section 144BA(12), section 144BA(13), section 144BA(14), section 95, section 96, section Rule 10UB, section Rule 10UC of the Income Tax Act 1961, in Assessment & Scrutiny, Appeals and How Tax Law Is Read matters.

Still good law. This is the statutory and rule text, not a decision about it. The section was read in full on two departmental pages carrying different current-vintage Year stamps (2026 and 2025) with identical wording for sub-sections (12), (13) and (14). Departmental rule pages carry no 'Year:' stamp, and the rule 10UB and rule 10UC pages print no amendment footnote either, so neither rule could be dated and both are stated as the department currently prints them; the rule 10UB page showed an upload date of 13/12/2025. Rule pages are not uniformly silent, however — the /w/rule-10u page does print amendment footnotes (see the separate Chapter X-A commencement entry) — so a rule page must be asked for its footnotes before it is treated as undatable. Later treatment was not checked against any decision construing section 144BA, and no decision striking down or reading down any part of the machinery was searched for.

Why it matters

Almost every practical answer to a GAAR notice is procedural, and the timetable is short and asymmetric. The assessee gets 'not exceeding sixty days' to object, and that period is fixed by the officer in the notice, not by the assessee. On the department's side Rule 10UC caps the Commissioner: no s.144BA(3) direction after one month from the end of the month in which the date of compliance with the s.144BA(2) notice falls, and no reference to the Approving Panel after two months from the end of the month in which the assessee's final submission is received. The Panel itself has six months from the end of the month of receipt of the reference under s.144BA(13), with the Explanation excluding treaty-information time (capped at one year) and stay periods, and a sixty-day floor if less than sixty days remain. Three traps. First, the bar on appeal in s.144BA(14) means an adverse Panel direction cannot be carried to the Commissioner (Appeals) or the Tribunal as a direction — the assessee's remedy is a writ against the direction, or an appeal against the assessment order that gives effect to it. Second, s.144BA(11) lets a direction reach other previous years without a fresh reference, so a single Panel direction can govern years that were never referred. Third, s.144BA(12) requires the Principal Commissioner's prior approval before the assessment order itself is passed where Chapter X-A consequences have been determined, and absence of that approval is a live ground. Note also that the Panel is not a departmental body: its Chairperson is or has been a High Court judge (s.144BA(16)), one member is an IRS officer not below Principal Chief Commissioner or Chief Commissioner, and one is an academic or scholar; it decides by majority under s.144BA(9), must hear both the assessee and the Assessing Officer on prejudicial directions under s.144BA(7), and has the powers of the Authority for Advance Rulings under s.245U by virtue of s.144BA(19).

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

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