CBDT Notification Clarifies Appellate Authority for Search and Survey Assessments

The Central Board of Direct Taxes issued Notification No. 170/2025 under section 120 of the Income-tax Act, 1961, reallocating appellate jurisdiction among specified Commissioners of Income-tax (Appeals) for search, requisition, and survey-related cases. The notification authorises designated appellate authorities across multiple locations to exercise powers over appeals arising from assessments completed pursuant to searches under section 132, requisitions under section 132A, or surveys under section 133A, including cases where additions are based on seized or impounded material and related penalty orders. This jurisdictional realignment applies to appeals under sections 246A and 248 and covers cases handled by specified Principal Commissioners and Commissioners of Income-tax, including Exemptions. By clearly mapping appellate authorities to defined classes of cases and jurisdictions, the notification aims to streamline appellate proceedings, ensure specialised handling of complex search-related matters, and promote administrative efficiency. The notification comes into force from the date of its publication in the Official Gazette.

MINISTRY OF FINANCE
(Department of Revenue)
(CENTRAL BOARD OF DIRECT TAXES)

Notification No. 170/2025-Income Tax | Dated: 15th December, 2025

S.O. 5799(E).—In exercise of the powers conferred by sub-sections (1) and (2) of section 120 of the Income-tax Act, 1961 (43 of 1961), and in continuation to the notification number S.O. 2907(E), dated the 13th November, 2014, published in the Gazette of India, Part II, Section 3, Sub-section (ii), the Central Board of Direct Taxes hereby directs that the Commissioner of Income-tax (Appeals) specified in column (2) of the Schedule annexed hereto, having their headquarters at the places specified in corresponding entries in column (3) of the Schedule, shall exercise the powers and perform the functions in respect of following class of cases, namely:-

i. appeals under sections 246A and 248 of the Income-tax Act, 1961 (43 of 1961) ( the said Act) against assessments completed in pursuance to search under section 132, requisition under section 132A or survey under section 133A of the said Act;

ii. appeals under sections 246A and 248 of the said Act against assessments where addition or change of income is made on the basis of material seized under section 132 or section 132A or impounded under section 133A of the said Act; and

iii. appeals under sections 246A and 248 of the said Act against penalty orders passed in category of cases mentioned in clauses (i) or (ii),

in respect of the persons or class of persons, for whom the Income-tax authorities specified in column (4) of the Schedule exercise the powers and perform the functions specified in the notification numbers S.O. 2752(E) dated the 22^nd October 2014 and S.O. 2754(E), dated the 22^nd October 2014.

SCHEDULE

2. This notification shall come into force form the date of its publication in the Official Gazette.

[Notification No. 170/2025/ F.No. 279/Misc./M-110/2025-ITJ]
DHRUV ASHTA, Under Secy. (ITJ-II), CBDT