(4)In case the assessee objects to the proposed action, and the [Principal Commissioner or Commissioner] [Substituted by Act 25 of 2014, section 4, for 'Commissioner' (w.e.f. 1-6-2013).] after hearing the assessee in the matter is not satisfied by the explanation of the assessee, then, he shall make a reference in the matter to the Approving Panel for the purpose of declaration of the arrangement as an impermissible avoidance arrangement.
