CBDT amends threshold of exclusions from e-Appeals Scheme 2023

CBDT amends scope of exclusions from e-Appeals Scheme 2023 by increasing threshold of disputed demand

CBDT amends scope of exclusions from e-Appeals Scheme 2023 by increasing threshold of disputed demand to Rs. 25 lakhs from Rs. 10 lakhs

CBDT vide Notification No. 33/2023 dated 29.05.2023 notified e-Appeals Scheme 2023 in respect of disposal of appeals by Joint Commissioner (Appeals). The Scheme applies to appeals, in respect of such persons or class of persons, incomes or class of incomes, cases or class of cases, as covered under section 246 of the Income Tax Act, 1961 (the Act) except the cases excluded under sub-section (6) of section 246.

Earlier, the CBDT had issued order u/s 246(6) dated 16.06.2023 specifying that appeals against the assessment orders passed before 13.08.2020 under section 143(3) or under section 144, having disputed amount more than Rs. 10 lakhs shall be excluded from the scope of the e-Appeals Scheme 2023.

The CBDT has issued a latest order under section 246(6) of the Act dated 17.09.2025 amending the above said exclusions criteria from e-Appeals Scheme 2023 as under:

The above amendments have become effective from 17.05.2025.

• Object of assessment proceedings is not to find empirically correct solution on every fact issue – HC
• Penalty u/s 270A deleted as assessee filed revised computation during scrutiny
• Penalty u/s 271B for unfilled column 40 in Tax Audit Report Form 3CD deleted by ITAT
• Merely ex-parte rectifying computation without amending assessment order not make it nullity- ITAT
• Once assessee discharges primary onus, it shifts to AO to bring evidence to contrary – ITAT