ITR
Drafting grounds of appeal
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Facts
Grounds are short numbered points that state what in the order is wrong, without long arguments. They go in Form 35 along with a separate statement of facts.
Provisions and law
- Sec 249, Income-tax Act 1961Appeal in Form 35 within 30 days of service of the demand or order, with the fee; delay can be condoned for sufficient cause; tax on returned income must be paid first (2025 Act number to be confirmed).
- Sec 250, Income-tax Act 1961The Commissioner (Appeals) fixes hearings, may allow additional grounds, and decides each ground with reasons (2025 Act number to be confirmed).
Analysis
Write each ground as one sentence, for example: 'The officer erred in adding ₹4,00,000 as unexplained cash deposit without considering the withdrawals shown.' Include a general ground reserving the right to add or change grounds. Additional grounds later are allowed only if the omission was not wilful, so cover all issues now.
Conclusion
- List every addition or error in the order.
- Write one numbered ground for each.
- Add a ground on interest if relevant.
- Add a general ground to alter or add grounds.
- Keep arguments for the written submission.
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Appeal to CIT(A), Form 35 (now Form 99)
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