Notification No. 170/2025, dated 15-12-2025
1. Background
The Central Board of Direct Taxes (CBDT) has issued a direction clarifying the appellate jurisdiction of the Commissioner of Income-tax (Appeals) [CIT(A)] in respect of assessments completed pursuant to search, requisition, or survey operations under the Income-tax Act, 1961.
This move aims to ensure administrative clarity, uniform handling of high-stakes assessments, and streamlined appellate proceedings in cases arising from enforcement actions.
2. Scope of Appeals Covered
The notified CIT(A) shall exercise appellate powers in respect of assessments completed under:
- Section 132 – Search and seizure
- Section 132A – Requisition from other authorities
- Section 133A – Survey operations
These assessments typically involve complex factual matrices, higher tax demands, and coordinated investigation outcomes, warranting specialised appellate handling.
3. CBDT Notification on Designated CIT(A)
CBDT has specifically notified the CIT(A) who shall hear and dispose of appeals against such assessments for a defined class of cases, based on territorial jurisdiction.
This ensures:
- Clear allocation of appellate authority
- Avoidance of jurisdictional disputes
- Faster disposal of search- and survey-related appeals
4. Locations for Designated CIT(A) Jurisdiction
CBDT has specified designated CIT(A)s for the following 24 locations:
- Hyderabad
- Visakhapatnam
- Bhubaneswar
- Patna
- Delhi
- Ahmedabad
- Surat
- Bengaluru
- Kochi
- Bhopal
- Raipur
- Mumbai
- Nagpur
- Ludhiana
- Gurgaon
- Pune
- Jaipur
- Udaipur
- Chennai
- Lucknow
- Kanpur
- Noida
- Kolkata
- Guwahati
Appeals arising from search/survey assessments in these jurisdictions must be filed before the designated CIT(A) notified for that location.
5. Regulatory Intent
The CBDT’s decision is aimed at:
- Ensuring specialised appellate oversight in search and survey cases
- Improving consistency and quality of appellate orders
- Reducing procedural delays caused by jurisdictional ambiguities
- Facilitating efficient resolution of high-value and investigation-based disputes
6. Implications for Taxpayers and Professionals
For Taxpayers
- Appeals must be filed before the correct designated CIT(A)
- Incorrect filing may lead to transfer delays or procedural objections
For Tax Professionals
- Careful jurisdiction mapping is required while drafting and filing appeals
- Strategic preparation is essential, given the focused jurisdiction handling search/survey matters
For the Department
- Enables centralised and expert handling of sensitive enforcement-driven assessments
- Enhances administrative efficiency and litigation management
7. Key Takeaway
Appeals against assessments completed under sections 132, 132A, and 133A must now be filed before CBDT-notified CIT(A)s for the specified jurisdictions. Taxpayers and advisors should ensure strict compliance with the notified appellate jurisdiction to avoid procedural setbacks.
Click Here To Read The Full Notification
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