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Income Tax Act 2025 · Appeals

Appeals & Dispute Resolution — Income-tax Act 2025

How to challenge an unfair assessment — the first appeal to the Commissioner (Appeals), the Tribunal (ITAT), revisions, and alternate dispute resolution.

Chapter XVIII of the Income-tax Act, 2025 gives you the right to challenge an assessment or penalty order through a tiered appeal system.

  • First appeal — Commissioner (Appeals) / faceless appeals: filed within the prescribed time after the order, on the grounds and statement of facts.
  • Income Tax Appellate Tribunal (ITAT): the second appeal and final fact-finding authority.
  • Revisions and alternate dispute resolution for specific cases.

Winning an appeal turns on precise grounds, a strong paper trail and case law. For high-value disputes see our CIT(A) Appeal and ITAT Appeal services.

Sections in this topic

§356
Section 356 of the Income-tax Act, 2025 — Appealable Orders Before the Joint Commissioner (Appeals)
Appealable orders before Joint Commissioner (Appeals)
§357
Section 357 of the Income-tax Act, 2025 — Appealable Orders Before the Commissioner (Appeals)
Appealable orders before Commissioner (Appeals)
§358
Section 358 of the Income-tax Act, 2025 — Form of Appeal and Limitation (First Appeal to CIT/JCIT (Appeals))
Form of appeal and limitation
§359
Section 359 of the Income-tax Act, 2025 — Procedure in Appeal Before the First Appellate Authority (JCIT(A) / CIT(A))
Procedure in appeal
§361
Section 361 of the Income-tax Act, 2025 — Constitution of the Income Tax Appellate Tribunal (ITAT)
Appellate Tribunal
§362
Section 362 of the Income-tax Act, 2025 — Appeals to the Appellate Tribunal (ITAT)
Appeals to Appellate Tribunal
§363
Section 363 of the Income-tax Act, 2025 — Orders of the Appellate Tribunal
Orders of Appellate Tribunal
§364
Section 364 of the Income-tax Act, 2025 — Procedure of the Appellate Tribunal (ITAT)
Procedure of Appellate Tribunal
§365
Section 365 of the Income-tax Act, 2025 — Appeal to the High Court (Substantial Question of Law)
Appeal to High Court
§366
Section 366 of the Income-tax Act, 2025 — Case Before High Court to Be Heard by Not Less Than Two Judges
Case before High Court to be heard by not less than two Judges
§367
Section 367 of the Income-tax Act, 2025 — Appeal to the Supreme Court
Appeal to Supreme Court
§368
Section 368 of the Income-tax Act, 2025 — Hearing Before the Supreme Court
Hearing before Supreme Court
§369
Section 369 of the Income-tax Act, 2025 — Tax to be Paid Irrespective of Appeal (No Automatic Stay of Demand)
Tax to be paid irrespective of appeal, etc
§370
Section 370 of the Income-tax Act, 2025 — Execution for Costs Awarded by the Supreme Court
Execution for costs awarded by Supreme Court
§371
Section 371 of the Income-tax Act, 2025 — Amendment of Assessment on Appeal (AOP/BOI Members)
Amendment of assessment on appeal
§372
Section 372 of the Income-tax Act, 2025 — Exclusion of Time Taken for Obtaining a Copy of the Order (Appeal Limitation)
Exclusion of time taken for copy
§373
Section 373 of the Income-tax Act, 2025 — Filing of Appeal by an Income-tax Authority (Departmental Appeals & Monetary Limits)
Filing of appeal by income-tax authority
§374
Section 374 of the Income-tax Act, 2025 — Interpretation of "High Court" for Tax Appeals
Interpretation of “High Court”
§375
Section 375 of the Income-tax Act, 2025 — Declaration to Avoid Repetitive Appeals When an Identical Question of Law is Pending Before the High Court or Supreme Court
High Court or Supreme Court
§376
Section 376 of the Income-tax Act, 2025 — Deferring Departmental Appeals When an Identical Question of Law Is Pending Before the High Court or Supreme Court
Or Supreme Court
§377
Section 377 of the Income-tax Act, 2025 — Revision of Orders Prejudicial to Revenue (Successor to Section 263)
Revision of orders prejudicial to revenue
§378
Section 378 of the Income-tax Act, 2025 — Revision of Other Orders in Favour of the Assessee (Successor to Section 264)
Revision of other orders
§379
Section 379 of the Income-tax Act, 2025 — Dispute Resolution Committee (DRC) for Small Taxpayers
Dispute Resolution Committee
§380
Section 380 of the Income-tax Act, 2025 — Interpretation (Definitions for Advance Rulings)
Interpretation
§381
Section 381 of the Income-tax Act, 2025 — Board for Advance Rulings (Constitution, Members and Powers)
Board for Advance Rulings
§382
Section 382 of the Income-tax Act, 2025 — Vacancies, etc., Not to Invalidate Proceedings of the Board for Advance Rulings
Section 382
§383
Section 383 of the Income-tax Act, 2025 — Application for Advance Ruling (Form 120)
Application for advance ruling
§384
Section 384 of the Income-tax Act, 2025 — Procedure on Receipt of an Advance-Ruling Application
Procedure on receipt of application
§385
Section 385 of the Income-tax Act, 2025 — Appellate Authority / Assessing Officer Not to Proceed When Advance Ruling Is Pending
Appellate authority not to proceed in certain cases
§386
Section 386 of the Income-tax Act, 2025 — Advance Ruling Declared Void for Fraud or Misrepresentation
Advance ruling to be void in certain circumstances
§387
Section 387 of the Income-tax Act, 2025 — Powers of the Board for Advance Rulings
Powers of the Board for Advance Rulings
§388
Section 388 of the Income-tax Act, 2025 — Procedure of the Board for Advance Rulings
Procedure of Board for Advance Rulings

Frequently asked questions

Where do I file the first appeal?
The first appeal against an assessment or penalty order goes to the Commissioner (Appeals) / faceless appeal centre, within the time limit specified in the order.
What is the ITAT?
The Income Tax Appellate Tribunal — the second-level appeal and the final fact-finding authority in the income-tax appeal system.
Disclaimer: Educational overview of the Income-tax Act, 2025 (effective 1 April 2026), not professional advice. Confirm your position with our team before acting.

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