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Case lawCBDT Circulars & Instructions › Statutory position — section 249: the fee, the thirty days, condonation, and the section 249(4) bar that must be cleared before the appeal is admitted
CBDT Circulars & InstructionsCuts both wayss.249s.249(1)s.249(2)s.249(3)s.249(4)s.246As.270AAs.146

Statutory position — section 249: the fee, the thirty days, condonation, and the section 249(4) bar that must be cleared before the appeal is admitted

I am filing a first appeal to the Commissioner (Appeals). What exactly must I have done before the appeal can even be admitted, and from what date do the thirty days run?

I am filing a first appeal to the Commissioner (Appeals). What exactly must I have done before the appeal can even be admitted, and from what date do the thirty days run?

Section 249(4) is a bar on admission, not a ground of dismissal on the merits: no appeal under Chapter XX shall be admitted unless, at the time of filing, the assessee has paid the tax due on the income returned (clause (a)) or, where no return was filed, an amount equal to the advance tax that was payable (clause (b)). Only clause (b) can be relaxed — on an application by the appellant, the Joint Commissioner (Appeals) or Commissioner (Appeals) may for any good and sufficient reason recorded in writing exempt him from clause (b); there is no such escape from clause (a). The appeal itself must be presented within thirty days of the date of service of the notice of demand (or, in the other cases, of intimation of the order appealed against), and s.249(3) lets the appellate authority admit a late appeal on sufficient cause.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2023-04-01, reported as Income-tax Act, 1961, s.249, as amended by the Finance Act 2023 (Act 8 of 2023) w.e.f. 1 April 2023. It bears on section 249, section 249(1), section 249(2), section 249(3), section 249(4), section 246A, section 270AA, section 146 of the Income Tax Act 1961, in Appeals matters.

Still good law. Sourced from the live departmental page, which prints the correct Act name and section heading and carries the stamp 'Year: 2025'; the footnote list on that page shows the only recent amendment to be the Finance Act 2023 insertion of the Joint Commissioner (Appeals). The text of s.249(4) and its proviso as reproduced here matches, save for the Finance Act 2023 insertion of the Joint Commissioner (Appeals) alongside the Commissioner (Appeals), the text set out by the Delhi High Court at paragraph 22 of CIT v. Jagat Novel Exhibitors Pvt. Ltd. (8 February 2012), transcribed this pass, which is an independent judicial reproduction of the pre-2023 wording. Whether any provision of the Income-tax Act, 2025 alters this for years beginning on or after 1 April 2026 has not been checked and nothing here should be read as a statement about that Act.

Why it matters

Practitioners lose appeals on this before anyone reads the grounds. Three things are commonly missed. First, the clause (a) obligation is to pay the tax on the RETURNED income — not the assessed demand — so an assessee who has filed a return showing tax and not paid it cannot be heard at all, however strong the merits. Second, the proviso is available only in a clause (b) case (no return filed), and it is available only on an application: the Commissioner (Appeals) cannot be assumed to have exercised the power silently. Third, s.249(2) counts thirty days from service of the NOTICE OF DEMAND in an assessment or penalty appeal, not from the date of the assessment order, which is often several days earlier; and two periods are expressly excluded — a pending s.146 application, and the period from a s.270AA immunity application to service of the order rejecting it. The second exclusion is the practically live one: an assessee who applies for immunity under s.270AA and is refused does not lose his appeal time while the application is pending.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

Not yet CA-verified. This entry was found through the sources listed under the Sources tab, and the summary reflects what those sources say. Nobody has yet read the full judgment and signed it off. Check the source before relying on it.

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Related

Other authorities on the same sections.