Threshold under e-appeal for legacy cases increased to ₹25 lakh

Legacy appeals refer to appeals filed before October 1, 2020, i.e., pre-faceless era
| Photo Credit:
Shutthiphong Chandaeng

Central Board of Direct Taxes (CBDT) has raised threshold for legacy issues under e-Appeal Scheme to ₹25 lakh from ₹10 lakh. The scheme, as part of faceless mechanism, aims to reduce pending appeals.

Legacy appeals refer to appeals filed before October 1, 2020, i.e., pre-faceless era. The board, as part of its central action plan, has instructed that focused efforts should be made to liquidate substantial number of appeals involving disputed amounts in legacy appeals. According to the board, as on April 1, 2025, number of total pending appeals, including legacy one, was 5.39 lakh with a total amount involving was over ₹16.60 lakh crore.

Ambitious target

The plan proposed to improve disposal of pending appeals and sets an ambitious target to dispose over 2 lakh appeals and about ₹10 lakh crore of disputed demand. According to officials, in FY25, the disposal of appeals was up 155 per cent more than the previous year at 1.72 lakh cases. This is the highest disposal till date in the history of the department, despite substantial manpower shortage and vacancies at the level of Commissioner (Appeals) (Faceless), and Joint CIT(A). Also, for first time, pendency of appeals as on April 1, 2025 was lower than the pendency on April 1, 2024, added officials.

The e-Appeals Scheme was notified in June 2023 as a follow-up to the FY24 budget announcement. Under this scheme, the Joint Commissioner (Appeals) has been assigned disposal of the appeal and this will be in addition to the Commissioner of the Income Tax-Appeal (CIT-A). Finance Minister Nirmala Sitharaman, in her budget speech for FY24, said: “To reduce the pendency of appeals at Commissioner level, I propose to deploy about 100 Joint Commissioners for disposal of small appeals.”

Later, the budget document explained that to expedite the disposal of certain appeals pending with Commissioner (Appeals), it is proposed to introduce a new authority in the rank of Joint Commissioner/ Additional Commissioner [JCIT(Appeals)], for appeals against certain orders passed by or with the approval of an authority below the rank of Joint Commissioner.

Under the scheme, on assignment of appeal, JCIT (Appeals) gives notice to the appellant asking him to file his submission within specified date and time. He may obtain further information, document or evidence from the appellant or any other person. He may ask the assessing officer for making further inquiry. He can also condone the delay in filing return.

In case of non-compliance of any notice, direction or order issued under this scheme on the part of the appellant or any other person, the JCIT (Appeals) may issue show cause notice for initiation of any penalty proceedings. Based on the response, the officer can impose the penalty or drop it.  All communication under the scheme is in electronic mode. There is no need for personal appearance for appellant under the scheme, but can be permitted based upon request.

Published on September 28, 2025