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Case lawCBDT Circulars & Instructions › Statutory position — Rules 10UD, 10UE and 10UF: the Approving Panel stage — Form 3CEIA, four sets, circulation within seven days, and the notice of hearing to both sides
CBDT Circulars & InstructionsCuts both waysRule 10UDRule 10UERule 10UFs.144BAs.144BA(4)s.144BA(6)s.144BA(7)s.144BA(8)s.144BA(9)s.144BA(13)s.144BA(14)Rule 10UBRule 10UC

Statutory position — Rules 10UD, 10UE and 10UF: the Approving Panel stage — Form 3CEIA, four sets, circulation within seven days, and the notice of hearing to both sides

The Commissioner has referred my case to the Approving Panel. What form does that reference take, what is the Panel obliged to do with it, and am I entitled to be heard?

The Commissioner has referred my case to the Approving Panel. What form does that reference take, what is the Panel obliged to do with it, and am I entitled to be heard?

Three rules govern this stage and they are short. Rule 10UD requires the reference under s.144BA(4) to be "made in Form No. 3CEIA along with a copy of Form No. 3CEI and such other documents which the Principal Commissioner or the Commissioner deems fit" and to be "submitted in four sets, either in Hindi or English". Rule 10UE(1) requires the Chairperson of the Panel to cause the reference to be circulated among the other members "within seven days from the date of receipt of such reference". Rule 10UE(2) requires the Chairperson to "cause to be issued the notice to the Assessing Officer and the assessee affording an opportunity of being heard specifying therein the date and place of hearing" — so the taxpayer's right to be heard before the Panel is in the rules as well as in s.144BA(7). Rule 10UE(3) leaves the venue of the Panel's meetings to the Panel. Rule 10UF fixes the members' remuneration at a sitting fee of six thousand rupees per day plus travelling and daily allowances as admissible to an officer of the rank of Special Secretary to the Government of India, met from the budgetary grants of the Department of Revenue.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2019-09-17, reported as Rules 10UD, 10UE and 10UF of the Income-tax Rules, 1962, transcribed from incometaxindia.gov.in/w/rule-10ud, /w/rule-10ue and /w/rule-10uf, none of which carries a "Year:" stamp; the set dated from amendment footnote 56 on the Rule 10UD page ("Rules 10UD to 10UF inserted by the IT (Eighth Amdt.) Rules, 2019, w.e.f. 17-9-2019"); Rule 10UD corroborated at indiankanoon.org/doc/88740808/ and Rule 10UE at indiankanoon.org/doc/54565575/. It bears on section Rule 10UD, section Rule 10UE, section Rule 10UF, section 144BA, section 144BA(4), section 144BA(6), section 144BA(7), section 144BA(8), section 144BA(9), section 144BA(13), section 144BA(14), 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. The three rules were inserted by the Income-tax (Eighth Amendment) Rules, 2019 with effect from 17 September 2019, on the amendment footnote printed on the departmental page for Rule 10UD (footnote 56), returned on two separate fetches and corroborated by the closing square bracket at the end of Rule 10UF. No footnote recording any later amendment is printed on any of the three pages, which is evidence — though not proof — that they stand as inserted. Rules 10UD and 10UE were each read on two routes, a departmental page and indiankanoon, which agreed word for word; Rule 10UF rests on the departmental page alone and is the weakest part of this entry. No judgment applying these three rules was found and no check of judicial treatment was made.

Why it matters

The rule set does not stop at Rule 10UC, and a practitioner who works from a checklist that ends there will miss the three rules that actually govern what happens once the reference leaves the Commissioner's office. Two of them are worth using. Rule 10UD identifies the documents: Form 3CEI is the Commissioner's own reference document and Form 3CEIA is the covering reference to the Panel, and both are documents the taxpayer should ask for, because the Panel is deciding on a case framed in them. Rule 10UE(2) is the taxpayer's entitlement to a notice specifying the date AND the place of hearing — a right that becomes real once you remember that Rule 10UE(3) allows the Panel to meet wherever it decides, so a hearing may be fixed in a city other than the one your assessment is in. The seven-day circulation requirement in Rule 10UE(1) is a useful marker for reconstructing the Panel's timeline — no decision has been found on whether it is mandatory or directory, so argue neither without authority — which matters because s.144BA(13) gives the Panel only six months from the end of the month in which the reference was received. Note what these rules do NOT do: they contain no provision for filing written objections to the Panel, no provision for representation, and no procedure for the further inquiry the Panel may direct under s.144BA(8). Those come from the section, and where the rules are silent the section is the source.

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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