Rule 131: Hearing before the GAAR Approving Panel
Rule 131 governs the initial procedure before the Approving Panel after it receives a reference. It requires circulation among members and a hearing notice to both the AO and the assessee.
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Rule 131 - Procedure before Approving Panel
(1) Upon receipt of reference under rule 129, the Chairperson of the Approving Panel shall cause, — (a) the reference to be circulated among the other members within seven days from the date of receipt of such reference; and (b) a notice to be issued to both the Assessing Officer and the assessee, affording a reasonable opportunity of being heard, specifying therein the date and place of hearing.
(2) The meetings of the Approving Panel shall take place at such place as the Approving Panel may decide.
Rule breakdown
Circulation within seven days
The Chairperson causes the reference to be circulated to the other members within seven days from receipt.
This is the internal circulation period stated by the rule; it should not be confused with a seven-day deadline for the assessee to file every submission.
Both sides receive a hearing notice
The notice is issued to the AO and the assessee, affording a reasonable opportunity of being heard and specifying the hearing’s date and place.
Check the notice and prepare the response and evidence relevant to the referred arrangement.
The Panel determines its meeting place
Meetings occur at the place the Approving Panel decides. The hearing notice supplies the stated details for attendance.
Follow the current official directions for the hearing rather than assuming the location from an earlier stage of the case.
Prepare a focused hearing file
Organise the reference, earlier notices, submissions, transaction documents and computation of the alleged tax benefit. Identify the points requiring clarification.
Retain the hearing notice and submission record for subsequent review of the proceeding.
Key takeaways
Seven-day circulation
The reference is circulated among members from receipt.
Reasonable hearing
Both AO and assessee receive the specified notice.
Date and place in notice
Use the issued hearing directions.
Practical checklist
- Check the hearing date and place.
- Prepare evidence tied to the reference.
- Keep notice and submission records.
Avoid
- Do not confuse internal circulation with a response deadline.
FAQs
Does the seven-day period automatically govern the assessee’s response?
It is the period for the Chairperson to circulate the reference to other members.
Must the assessee receive a hearing opportunity?
The rule requires a notice affording a reasonable opportunity of being heard.
Who determines the meeting place?
The Approving Panel.
Glossary
- Approving Panel hearing
- The opportunity provided through the notice described in Rule 131(1)(b).