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Section 236 · Administration

Section 236 of the Income-tax Act, 2025 — Classes of Income-tax Authorities Explained

By CA Rajat Agrawal Updated 04 Jul 2026 Chapter XIV
📜 What the law says — Section 236, Income-tax Act 2025
236. For the purposes of this Act, there shall be the following classes of income-tax authorities:— (a) the Central Board of Direct Taxes constituted under the Central Boards of Revenue Act, 1963 (54 of 1963); (b) Principal Directors General of Income-tax or Principal Chief Commis- sioners of Income-tax; (c) Directors General of Income-tax or Chief Commissioners of Income-tax; (d) Principal Directors of Income-tax or Principal Commissioners of Income-tax; (e) Directors of Income-tax or Commissioners of Income-tax or Commis- sioners of Income-tax (Appeals); (f) Additional Directors of Income-tax or Additional Commissioners of Income-tax or Additional Commissioners of Income-tax (Appeals); (g) Joint Directors of Income-tax or Joint Commissioners of Income-tax or Joint Commissioners of Income-tax (Appeals); (h) Deputy Directors of Income-tax or Deputy Commissioners of Income- tax; (i) Assistant Directors of Income-tax or Assistant Commissioners of Income-tax; (j) Income-tax Officers; (k) Tax Recovery Officers; and (l) Inspectors of Income-tax. Appointment of income-tax authorities.

In plain language

What Section 236 says in plain English

Section 236 is the "org chart" of India's income-tax department. It does not tax you, charge you interest or impose a penalty. Instead, it simply lists, in descending order of seniority, the 12 classes of officials who are legally recognised as "income-tax authorities" under the Income-tax Act, 2025 (in force from 1 April 2026). Every notice, assessment order, refund, penalty or recovery action you ever receive must come from one of these 12 classes of authority — nobody else has the legal power to act.

Section 236 is the direct successor to Section 116 of the old Income-tax Act, 1961. The list of authorities is virtually unchanged; the 2025 Act simply re-numbers and re-groups the designations for cleaner drafting.

The 12 classes of income-tax authorities

  • (a) Central Board of Direct Taxes (CBDT) — the apex policy body, constituted under the Central Boards of Revenue Act, 1963.
  • (b) Principal Directors General / Principal Chief Commissioners of Income-tax.
  • (c) Directors General / Chief Commissioners.
  • (d) Principal Directors / Principal Commissioners.
  • (e) Directors / Commissioners / Commissioners (Appeals).
  • (f) Additional Directors / Additional Commissioners / Additional Commissioners (Appeals).
  • (g) Joint Directors / Joint Commissioners / Joint Commissioners (Appeals).
  • (h) Deputy Directors / Deputy Commissioners.
  • (i) Assistant Directors / Assistant Commissioners.
  • (j) Income-tax Officers (ITOs).
  • (k) Tax Recovery Officers (TROs) — the officials who recover unpaid demand.
  • (l) Inspectors of Income-tax.

Who it applies to

Section 236 applies to the department, not directly to taxpayers — but it matters deeply to every taxpayer. It is the foundation on which the rest of Chapter XIV (Tax Administration) is built. Sections 237 to 245 then explain how these authorities are appointed, controlled, given jurisdiction and now operate in faceless mode.

Key points and conditions

  • Fixed hierarchy. Seniority flows top-down. A senior authority can supervise, instruct and review the work of a junior one; the reverse is not allowed.
  • "Assessing Officer" is a role, not a rank. Your Assessing Officer (AO) is usually an Income-tax Officer or an Assistant/Deputy Commissioner who has been given jurisdiction over your case under Section 242.
  • Two vertical wings. The "Director" line handles investigation/intelligence; the "Commissioner" line handles regular assessment and administration. Both are equal in rank.
  • Appeals sit inside the list. Commissioner (Appeals), Additional Commissioner (Appeals) and Joint Commissioner (Appeals) are your first level of appeal within the department.

How it interacts with related sections

  • Section 237 empowers the Central Government / CBDT to actually appoint these authorities.
  • Section 238–239 deal with control and binding instructions to subordinate officers.
  • Sections 241–242 fix jurisdiction — which authority handles which taxpayer/area.
  • Section 243 lets cases be transferred between authorities; Section 245 introduces faceless assessment, where the human officer's identity is hidden.

Practical implications for you

  • Check the designation on every notice. A valid order must be issued by an authority listed in Section 236 and acting within its jurisdiction — otherwise it can be challenged.
  • Know your appeal ladder. After an AO's order, you appeal to a Commissioner (Appeals) — one of the classes named here — before going to the Income-tax Appellate Tribunal.
  • Recovery contact point. If you default on a demand, it is the Tax Recovery Officer (class k) who can attach your bank account or property.
💡 Example

Worked example 1 — Reading a notice. Ramesh, a salaried employee in Jaipur, receives a scrutiny notice for a return declaring ₹18,00,000 income. The notice is signed by an "Assistant Commissioner of Income-tax, Circle 3(1)". Because "Assistant Commissioner" is a recognised class under Section 236(i) and the officer has jurisdiction under Section 242, the notice is valid and Ramesh must respond. Had it come from, say, a "Bank Manager" or an unlisted designation, it would carry no legal force.

Worked example 2 — The appeal ladder. A small business is assessed with an extra demand of ₹2,40,000 by its Income-tax Officer (class j). Unhappy, the firm files a first appeal to the Commissioner (Appeals) under class (e). If still aggrieved, it moves to the Income-tax Appellate Tribunal (which sits outside Section 236). Section 236 tells you exactly which departmental authority hears that first appeal.

A relatable story. Meena ignored a ₹95,000 tax demand for two years. One morning she got a bank-attachment order and panicked, thinking it was a scam. Her CA showed her that the order was from the "Tax Recovery Officer" — a genuine authority named in Section 236(k) — with full power to attach her account. Meena paid the dues and got the attachment lifted. Knowing the 12 classes helped her tell a real authority from a fake.

ClauseClass of authority (2025 Act)Main role
(a)Central Board of Direct Taxes (CBDT)Apex policy, oversight, rules
(b)Principal Directors General / Principal Chief CommissionersRegion/zone heads
(c)Directors General / Chief CommissionersSenior zonal administration
(d)Principal Directors / Principal CommissionersCharge-level heads
(e)Directors / Commissioners / Commissioners (Appeals)Administration & first appeals
(f)Additional Directors / Additional Commissioners (Appeals)Range supervision & appeals
(g)Joint Directors / Joint Commissioners (Appeals)Range/appeal work
(h)Deputy Directors / Deputy CommissionersAssessment / investigation
(i)Assistant Directors / Assistant CommissionersAssessment (often AO)
(j)Income-tax Officers (ITO)Assessment (often AO)
(k)Tax Recovery Officers (TRO)Recovery of unpaid demand
(l)Inspectors of Income-taxField verification, support

Related sections

Section 237 — Appointment of income-tax authorities Section 238 — Control of income-tax authorities Section 239 — Instructions to subordinate authorities Section 241 — Jurisdiction of income-tax authorities Section 242 — Jurisdiction of Assessing Officers Section 245 — Faceless jurisdiction of income-tax authorities

Frequently asked questions

What does Section 236 of the Income-tax Act, 2025 actually do?
It lists the 12 classes of officials who are legally recognised as income-tax authorities, from the CBDT at the top down to Inspectors of Income-tax. It creates the department's hierarchy but does not itself impose any tax.
Is Section 236 the same as Section 116 of the old Act?
Yes. Section 236 of the 2025 Act is the successor to Section 116 of the Income-tax Act, 1961. The list of authorities is essentially the same, with cleaner drafting and re-grouped designations.
Who is the highest income-tax authority under Section 236?
The Central Board of Direct Taxes (CBDT), constituted under the Central Boards of Revenue Act, 1963, is the apex authority listed at clause (a).
Is my 'Assessing Officer' one of these authorities?
Yes. The Assessing Officer is a role usually filled by an Income-tax Officer or an Assistant/Deputy Commissioner — all named in Section 236 — who has been given jurisdiction over your case under Section 242.
Who can recover unpaid tax from me?
The Tax Recovery Officer, listed at clause (k) of Section 236, is the authority empowered to recover unpaid demand, including by attaching bank accounts or property.
Whom do I appeal to if I disagree with my tax order?
Your first departmental appeal goes to a Commissioner (Appeals), Additional Commissioner (Appeals) or Joint Commissioner (Appeals) — all classes named in Section 236 — before you can approach the Income-tax Appellate Tribunal.
When did Section 236 come into effect?
It takes effect from 1 April 2026, along with the rest of the Income-tax Act, 2025 (as amended by the Finance Act, 2026).
C
CA Rajat Agrawal
Chartered Accountant, EaseValue · Reviewed 04 Jul 2026
This explainer is prepared and reviewed by EaseValue's tax team, based on the text of the Income-tax Act, 2025 (as amended by the Finance Act, 2026).
Disclaimer: This page explains the law in general terms for education and is not professional advice. The Income-tax Act, 2025 takes effect from 1 April 2026; provisions, thresholds and interpretations may change. Please confirm your specific position with our team before acting.

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