Form for making the reference to the Commissioner of Income-tax by the Assessing Officer under section 274(1)

Part A: Particulars ofthe Assessee

1.

Name:

(refer Note 1)

2.

Address:

(refer Note 2)

3.

Permanent Account Number (PAN):

4.

E-mail Id:

5.

Contact Number:

Country

Code

Number

6.

Document Identification Number:

Part B: Other Information

7.

Status:

(refer Note 3)

8.

Residential Status:

(refer Note 4)

9.

Tax Year(s) in respect of which the proceedings under section 274 are proposed to be invoked:

(i)

Tax Years for which proceedings are pending:

(ii)

Other tax years proposed to be covered:

10.

The last date for completion of assessment or reassessment proceedings:

11.

Brief reasons for seeking declaration of the arrangement as impermissible avoidance arrangement:

12.

Other details to be provided as separate enclosure:

(attach as per Note 5)

(I)

Individual

(II)

Hindu undivided family

(III)

Company

(IV)

Firm

(V)

Association of Persons or Body of individuals, whether incorporated or not

(VI)

Local authority

(VII)

Artificial Juridical Person

(VIII)

Government

(IX)

Trust

(X)

Limited Liability Partnership

(I)

Resident

(II)

Non-resident

(III)

Resident but Not Ordinarily Resident

Anne

xure

. .

Particulars

A-1

Factual matrix of the arrangement entered into by the assessee including details of other parties.

A-2

Details of tax benefit (Tax Year-wise) arising under the arrangement: —

(x) to the assessee;

(xi) to all parties to the arrangement.

A-3

Brief facts in respect of computation of tax benefit.

A-4

Whether obtaining the tax benefit is the main purpose of the arrangement or part of the arrangement?

A-5

Whether notice under rule 129(1) has been served on the assessee, if yes date of service of the notice.

A-6

Summary of the reply of the assessee in response to the notice.

A-7

Indicate which of the following conditions is satisfied by the arrangement (along with basis of such conclusion): —

(i) creates rights, or obligations, which are not ordinarily created between persons dealing at arm's length;

(ii) results, directly or indirectly, in the misuse, or abuse, of the provisions of this Act;

(iii) lacks commercial substance or is deemed to lack commercial substance under section 180, in whole or in part; or

(iv) is entered into, or carried out, by means, or in manner, which are not ordinarily employed for bona-fide purposes.

A-8

Consequences in relation to tax likely to arise if the arrangement is declared as an impermissible avoidance arrangement.