The Income Tax Gazetted Officers’ Association submitted a representation to the CBDT highlighting systemic causes behind delays in filing and tracking departmental appeals, in light of a recent Delhi High Court warning against mechanically justified delayed appeals and the imposition of daily penal costs. The Association endorsed the Court’s call for accountability but stressed that delays often stem from institutional shortcomings rather than individual lapses. It attributed major difficulties to the abrupt merger of JAO charges during 2019–2020, which resulted in excessive workloads, lack of proper handovers, inadequate staff support, and deficient IT systems. The letter further pointed out persistent problems in tracking appeal status, especially before High Courts and the Supreme Court, where field officers are often not informed of filing details or case numbers. To address these issues, the Association proposed a centralized digital, real-time appeal tracking mechanism, better institutional monitoring by senior अधिकारियों, and merit-based decisions on filing appeals, advocating a shift from individual blame to collective responsibility.
Income Tax Gazetted Officers’ Association
President
ARAVIND TRIVEDI
(7599101090)
trivediaravind@yahoo.co.in
Secretary General
BHASKAR BHATTACHARYA
(8902198888)
secgenitgoachq@gmail.com
Date: 27-01-2026
To
The Chairman,
Central Board of Direct Taxes,
North Block, New Delhi.
Respected Sir,
Sub: Envisaging a robust mechanism for Real-Time Status Updates of filed appeals for Departmental Officers and filing of appeals- reg.
Your kind attention is invited to a recent judgment of the Hon’ble Delhi High Court, wherein the Hon’ble Bench expressed concern over the filing of belated appeals supported by routine and mechanical explanations citing procedural delays. The Hon’ble Court advised the Principal CCIT to put in place an effective mechanism to ensure timely filing of appeals and to permit delayed filing only where supported by cogent justification. The Hon’ble Court further cautioned that any appeal filed beyond the prescribed limitation without proper justification would henceforth attract a penal cost of Rs. 5,000 per day. Pursuant to the said judgment, the office of the Principal CCIT, Delhi, circulated the directions of the Hon’ble Court, including the observation regarding initiation of appropriate administrative action against erring officer(s), wherever deemed fit.
We respectfully endorse the Hon’ble Court’s observation that the time has come for the Income Tax Department to put its house in order. This imperative calls for a holistic and institutional response, one that identifies systemic constraints, evolves workable solutions and fosters shared ownership of responsibilities, rather than an approach, unfortunately practiced in our Department that places the entire burden on the hapless assessing officers alone. It is respectfully submitted that as with several other issues faced in JAO charges, the genesis of the delay in filing the appeal can be traced to the sudden and unplanned merger of JAO charges during 2019 and 2020. In many instances, four to six, and at times even eight, wards/circles were merged overnight into a single unit. The newly posted incumbents were required to assume charge of these merged units without the benefit of proper handover notes or adequate visibility of pending judicial matters. Consequently, such pending cases surfaced only over a period of time, resulting in an unintended and prolonged delay in the filing of appeals.
Since the merger of JAO charges, no systemic measures appear to have been taken to mitigate the adverse effects of this unplanned reorganisation, either by rationalising the charges or by streamlining their functioning. As a result, JAO charges continue to be assigned a wide range of tasks with unrealistic timelines, leaving little scope for effective housekeeping. This is further compounded by the burden of avoidable reporting, inadequate staff support and deficient departmental systems (ITBA etc.). The Hon’ble Courts, understandably, may not be apprised of such internal administrative constraints while issuing directions. However, at the implementation stage, these constraints are overlooked and the entire onus is placed on individual JAOs, disregarding institutional shortcomings and the principle of collective responsibility. The recent development in Delhi, referred to above, is another manifestation of this systemic issue.
Even in cases where appeals have already been filed, status tracking continues to remain a major concern. At the outset, when a case is filed before the Hon’ble Supreme Court, the field offices are often not duly informed and, more importantly, the Diary Number or the subsequent SLP Number is not shared with them. As a result, JAOs are required to trace such cases through the Supreme Court’s official website, which itself may pose practical difficulties. The problem becomes more acute when a large number of cases, sometimes exceeding a hundred, are tagged on the basis of common issue(s) and proceedings are reported only in the lead case. In such situations, it becomes extremely difficult for an individual JAO to track the progress of his or her own case. Further, after the merger of charges in 2020, there is no exhaustive list of cases pending before the Hon’ble High Courts or Supreme Court for a given JAO charge and the JAOs are too preoccupied to carve out the necessary time to compile such a list. Consequently, compliance with court directions, effective representation and timely giving effect to judicial orders suffer, which may ultimately lead to adverse observations or directions from the Hon’ble Courts, with the individual JAOs inevitably finding themselves on the receiving end.
In view of the above and with a view to genuinely putting the house in order rather than placing the entire onus on the junior-most officers in the litigation management hierarchy, it is proposed that the Department should prepare an exhaustive list of all pending cases before the Hon’ble Supreme Court and the Hon’ble High Courts in coordination with the respective registries, develop a digital platform and/or message/alert-based system to keep JAOs informed of filing status, case numbers upon filing, hearing schedules and order/judgment status, sensitize the PCsIT/CsIT to optimally utilize their good offices to effectively monitor, support (through a dedicated cell or team in his office) and handhold JAOs and other subordinate authorities for timely filing of appeals, and also sensitize collegium members and PCsIT/CsIT to recommend filing of appeals strictly on merit and not mechanically based on monetary limits.
As you are at the helm of affairs, we sincerely and respectfully believe that these concerns will receive your kind, sympathetic and thoughtful consideration, that the suggestions made herein will be examined and acted upon as deemed appropriate and that the principle of collective responsibility will be meaningfully upheld.
This is for your kind consideration and necessary action.
Thanking You,
Yours Sincerely,
(Bhaskar Bhattacharya)
Secretary General
