Tax Litigation & Representation · Notices & Appeals
Whether it is a demand you don’t owe, a reassessment reopening an old year, or an addition that should never have been made, there is a defined route out, rectify, respond, or appeal. We pick the right one, get the demand stayed where it matters, and argue the appeal through to the Tribunal.
A tax demand has been raised that you dispute, or that you need stayed while you appeal.
An old year is being reopened, the 148A inquiry or the 148 notice has arrived.
A 143(3) assessment added income you disagree with and you want to appeal to CIT(A).
A penalty under Section 270A or 271 has been proposed and needs a reasoned reply.
An intimation made a wrong adjustment that should be set right by rectification under Section 154.
The first appeal didn’t go your way and you want to take it to the Tribunal (ITAT).
| Step | What happens |
|---|---|
| Diagnose the notice | Identify the provision, the deadline, and whether the answer is rectify, reply, or appeal. |
| Protect cash flow | Where a demand is raised, apply for a stay so recovery doesn’t run while the appeal is pending. |
| Build the grounds | Draft grounds of appeal and a statement of facts anchored in evidence and case law. |
| File the appeal | Form 35 to the Commissioner (Appeals), filed within the 30-day window with the fee paid. |
| Argue it | Submissions and the faceless hearing handled, responding to every query raised. |
| Escalate if needed | If the order still stands, appeal to the ITAT, and advise on High Court where a question of law arises. |
| Forum | Filed as | When | Time limit |
|---|---|---|---|
| Commissioner (Appeals) | Form 35 (faceless) | First appeal against an assessment or penalty order | 30 days from order |
| ITAT | Form 36 | Appeal against the CIT(A) order | 60 days from order |
| High Court | Tax appeal | Only on a substantial question of law | 120 days |
| Supreme Court | SLP / appeal | Final forum on the question of law | As prescribed |
Government / statutory cost
Professional fees depend on the forum, the issues and the years involved. You receive a clear written quote after we read the notice or order on a short call, no hidden charges, no published menu.
Send us the notice, book a 15-minute callA first appeal to the Commissioner (Appeals) must be filed in Form 35 within 30 days of receiving the order. An appeal to the Income-Tax Appellate Tribunal is filed in Form 36 within 60 days. Delays can sometimes be condoned for sufficient cause, but the safe course is to file within the window.
It can, unless you obtain a stay. The CBDT norm is that paying 20% of the disputed demand generally secures a stay of the remaining amount until the first appeal is decided. We apply for the stay so recovery action, such as bank attachment, does not begin.
It reopens an earlier year on the basis that income escaped assessment. Since the Finance Act 2021, it is preceded by a Section 148A inquiry giving you a chance to respond before the notice is issued. Reassessment is generally limited to three years, extended for high-value escaped income of Rs 50 lakh or more, subject to the statutory conditions. We respond at the 148A stage and, if the notice still issues, defend the reassessment.
It depends on the problem. A clear, apparent mistake, a wrong tax credit, an arithmetic error, a TDS not given, is fixed faster and cheaper by a Section 154 rectification than by appeal. A dispute on the merits of an addition needs an appeal. We advise which route actually solves your case.
Yes. First appeals before the Commissioner (Appeals) are conducted through the faceless appeal system, submissions and hearings are online. We handle the portal, the written submissions and the video hearing for you.
Yes. Penalties, for example under Section 270A for under-reporting (50%) or misreporting (200%) of income, require a separate reasoned reply, and can be appealed. Often the penalty falls away once the underlying addition is deleted in the quantum appeal.
You can appeal to the Income-Tax Appellate Tribunal (ITAT) in Form 36 within 60 days. The ITAT is the final fact-finding authority; beyond it, an appeal to the High Court lies only on a substantial question of law. We represent you at the Tribunal and advise on whether a High Court appeal is warranted.
Yes. We handle scrutiny and assessment under Sections 143(2), 142(1) and 143(3) as well, detailed on our scrutiny & assessment page, so the same team that knows the facts argues the appeal.
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Vijay R Singh & Co., Chartered Accountants · FRN 136869W · ICAI M.No. 153926 · Andheri East, Mumbai, in practice since 2013. Section references are to the Income-tax Act 1961; for FY 2026-27 onward the Income-tax Act 2025 carries equivalent provisions. Outcomes depend on the facts and records of each case; nothing here is a representation of result. General information, not tax advice until engaged.
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