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Knowledge Bank / Income-tax Act, 2025 / Chapter XVIII - APPEALS, REVISIONS AND ALTERNATE DISPUTE RESOLUTIONS

Section 357

Section 357: appealable orders before the Commissioner (Appeals)

Section 357 sets out the orders that an aggrieved assessee, deductor or collector may appeal against before the Commissioner (Appeals). It is broader than the Joint Commissioner (Appeals) route in section 356, covering assessments, reassessments, penalties, and a long list of specific orders passed under named provisions of the Act.

This explanation is AI-assisted and pending review by our CA/CS team. It is general information, not professional advice - always cross-check against the bare law text above or talk to our tax team for guidance specific to your situation.

Orders that can be appealed to the Commissioner (Appeals)

Under Section 357, an assessee, deductor or collector aggrieved may appeal against:

  • An order passed by a Joint Commissioner under section 231(4)(b)
  • An order against the assessee where the assessee denies liability to be assessed under the Act
  • An intimation under section 270(1) or 399(1), where adjustments are objected to
  • An assessment order under section 270(10) or 271 (except one passed under Dispute Resolution Panel directions, or an order under section 274(12)), where the assessee objects to the income assessed, tax determined, loss computed, or status of assessment
  • An order of assessment, reassessment or recomputation under section 279 (with the same DRP/section 274(12) exception) or under section 283
  • An order under section 169(3)(a)
  • An order under section 287 or 288 that enhances the assessment, reduces a refund, or refuses a claim (except an order under section 274(12))
  • An order under section 306 treating the assessee as agent of a non-resident
  • An order under section 313(2) or (4)
  • An order under section 315
  • An order under section 398
  • An order under section 431
  • An order under section 434
  • An order imposing or enhancing a penalty under Chapter XXI
  • An order imposing a penalty under section 412
  • An order under section 294(1)(c)
  • An order imposing a penalty under section 298(2)
  • An order made by an Assessing Officer for such persons or class of persons as the Board may direct, having regard to the nature of cases and their complexity

Frequently asked questions

Is Section 357 wider than Section 356's appeal route?

Yes - Section 357 lists a much longer range of appealable orders before the Commissioner (Appeals), including specific orders under sections such as 231(4)(b), 306, 313, 315, 398, 431 and 434, in addition to standard assessment and penalty orders.

Can an assessment passed on Dispute Resolution Panel directions be appealed under Section 357?

No - Section 357 specifically excludes an order of assessment passed in pursuance of directions of the Dispute Resolution Panel, and also excludes an order referred to in section 274(12), from the assessment/reassessment appeal clauses.

Related sections

  • Section 356 - appealable orders before Joint Commissioner (Appeals)
  • Section 358 - form of appeal and limitation
  • Section 360 - powers of Commissioner (Appeals)

Want this applied to your actual filing, not just explained?

Get help responding to an income-tax order or notice

Last updated 9 September 2026

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