The Central Board of Direct Taxes (CBDT) has issued a fresh notification redefining the jurisdiction and functional powers of several Commissioners of Income Tax (Appeals) [CIT(A)] across the country. The notification, dated 15 December 2025, has been published in the Gazette of India (Extraordinary) and comes into effect from the date of its publication
What the Notification Is About
Under the powers granted by Section 120(1) and 120(2) of the Income-tax Act, 1961, the CBDT has specified which Commissioners of Income Tax (Appeals) will handle appeals arising from search, seizure, requisition, and survey cases.
The notification applies to appeals filed under Sections 246A and 248 of the Income Tax Act, particularly where assessments or additions are made based on material seized or impounded during:
- Search under Section 132
- Requisition under Section 132A
- Survey under Section 133A
It also covers appeals against penalty orders passed in such cases
Key Categories of Appeals Covered
The jurisdictional allocation applies to the following classes of cases:
- Appeals against assessments completed pursuant to search, requisition, or survey proceedings
- Appeals where additions or changes in income are based on seized or impounded material
- Appeals against penalty orders arising from the above categories of assessments
This move aims to streamline appellate proceedings in complex search and survey-related matters.
Nationwide Reallocation of Appellate Jurisdiction
The notification includes an extensive Schedule specifying:
- Designation of the Commissioner of Income Tax (Appeals)
- Their headquarters
- The Principal Commissioners or Commissioners of Income Tax whose cases will fall under their appellate jurisdiction
Major cities covered include Delhi, Mumbai, Chennai, Kolkata, Bengaluru, Hyderabad, Pune, Ahmedabad, Jaipur, Lucknow, Kochi, Bhopal, Guwahati, and several others, ensuring pan-India coverage.
Why This Matters for Taxpayers and Professionals
This reallocation is significant for:
- Taxpayers facing search or survey assessments, as it determines the correct appellate authority
- Chartered Accountants and tax advocates, who must now ensure appeals are filed before the correctly designated CIT(A)
- Litigation strategy, as jurisdictional clarity avoids procedural defects and delays
Filing an appeal before an incorrect authority can lead to unnecessary litigation and loss of time, making this notification particularly important for ongoing and future cases.
Continuation of the Earlier Framework
The notification is issued in continuation of earlier CBDT notifications dated 22 October 2014 and 13 November 2014, maintaining consistency while updating jurisdictional assignments based on administrative requirements
Effective Date
The notification comes into force immediately from the date of its publication in the Official Gazette, i.e., 15 December 2025.
Official copy of the notification has been attached
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