The Ministry of Finance has released detailed five-year data on pending income tax disputes across various appellate forums, showing that lakhs of cases remain unresolved and over Rs 16 lakh crore (in disputed amounts) continue to be locked up at different stages. The information was provided in a written reply by Minister of State for Finance, Shri Pankaj Chaudhary, to an unstarred question in the Rajya Sabha.
Lakhs of Appeals Pending Before First Appellate Authority
According to the data, the First Appellate Authority [CIT(A)/JCIT(A)] continues to witness the highest pendency. As of FY 2024-25 alone, 5,39,863 appeals were pending, involving a disputed amount of Rs 16,75,45,696 lakh. The trend over the last five years shows consistently high pendency:
- FY 2020-21: 4,48,992 appeals; disputed amount Rs 24,52,30,069 lakh
- FY 2021-22: 5,02,111 appeals; disputed amount Rs 14,18,63,134 lakh
- FY 2022-23: 5,25,367 appeals; disputed amount Rs 16,33,98,912 lakh
- FY 2023-24: 5,48,278 appeals; disputed amount Rs 16,90,42,426 lakh
These figures highlight the growing caseload and the significant revenue locked up at the first appellate stage.
ITAT, High Courts, and the Supreme Court Also Hold Large Pending Tax Disputes
The Ministry also shared forum-wise data for the Income Tax Appellate Tribunal (ITAT), High Courts, and the Supreme Court. As of FY 2024-25:
- ITAT: 22,960 appeals pending; disputed amount Rs 3,64,45,449 lakh
- High Courts: 34,486 cases pending; disputed amount Rs 5,65,15,885 lakh
- Supreme Court: 6,338 cases pending; disputed amount Rs 25,40,351 lakh
A comparison over five years reveals fluctuating pendency but steadily increasing disputed amounts, especially in the High Courts, where the amount rose from Rs 2,75,32,925 lakh in FY 2020-21 to Rs 5,65,15,885 lakh in FY 2024-25.
Dispute Data Classified Across Appellate Levels
Responding to queries on the classification of disputes, the Ministry confirmed that the Income Tax Department maintains separate records for each appellate level:
- First Appellate Authority [CIT(A)/JCIT(A)]
- ITAT
- High Courts
- Supreme Court of India
This structured tracking helps analyse pendency and dispute resolution progress across the tax litigation framework.
High Pendency Highlights Litigation Burden
The data underscores a systemic challenge-high pendency and massive disputed amounts locked for years at all judicial and quasi-judicial levels. Tax professionals say that reducing litigation and speeding up case disposal remain critical to lowering compliance costs and improving ease of doing business.
Official copy of the data has been attached
CAclubindia
