In a significant administrative move aimed at streamlining the appellate process under the Income-tax Act, the Central Board of Direct Taxes (CBDT) has issued Notification No. 170/2025, formally assigning jurisdiction and functional powers to designated Commissioners of Income Tax (Appeals) for handling appeals arising out of search, seizure, requisition, and survey proceedings.
The notification has been issued in exercise of the powers conferred under Section 120(1) and 120(2) of the Income-tax Act, 1961, and continues the framework earlier laid down by a 2014 notification. Under the new arrangement, specified Commissioners of Income Tax (Appeals), headquartered across major cities, will exclusively exercise appellate powers in certain categories of high-stakes assessment and penalty matters linked to enforcement actions by the tax department
As per the notification, the Commissioners (Appeals) will adjudicate appeals filed under Sections 246A and 248 of the Act against assessments completed pursuant to searches under Section 132, requisitions under Section 132A, or surveys under Section 133A. This includes cases where additions or modifications to income have been made based on materials seized, requisitioned, or impounded during such proceedings
The jurisdiction also extends to appeals against penalty orders passed in connection with these search- and survey-related assessments. By consolidating such cases under designated appellate authorities, the CBDT aims to ensure greater consistency, specialization, and efficiency in handling complex litigation involving undisclosed income and enforcement actions
The notification annexes a detailed Schedule listing 47 Commissioners of Income Tax (Appeals) located in cities including Hyderabad, Delhi, Mumbai, Ahmedabad, Bengaluru, Chennai, Kolkata, Pune, Jaipur, Lucknow, Guwahati, and others. Each appellate authority has been mapped to specific Principal Commissioners of Income Tax and Commissioners of Income Tax (Exemptions) whose cases will fall within their appellate jurisdiction. This extensive geographical coverage underscores the nationwide application of the revised appellate structure
Tax professionals note that the move is likely to bring procedural clarity for taxpayers whose assessments originate from search and survey actions, which often involve voluminous records and complex factual issues. Centralising such appeals with designated Commissioners (Appeals) is expected to reduce jurisdictional confusion and expedite disposal of cases that traditionally remain pending for long periods.
The notification clarifies that all powers and functions assigned under this order will be exercised in respect of persons or classes of persons already notified under earlier CBDT notifications issued in October 2014. By reinforcing and updating the appellate framework, the CBDT has reiterated its intent to strengthen tax administration while ensuring structured adjudication of disputes arising from enforcement-driven assessments.
Notification Details
Notification No. 170/2025
Date: 15/12/2025
Read More: Centre Extends Anti-Dumping Duty on Chinese Faced Glass Wool Rolls Till June 2026
