How We Handle Your CIT(Appeals)/NFAC Appeal

Where an assessment order results in additions or disallowances you wish to contest, the first appellate remedy lies before the Commissioner of Income-tax (Appeals), functioning through the National Faceless Appeal Centre (“NFAC”). Like the assessment itself, the appeal is conducted electronically — grounds of appeal, submissions and evidence are filed and argued through the Income-tax Portal, generally without a personal hearing unless one is specifically sought and granted.

Why Professional Representation Matters

An appeal is only as strong as the grounds and the record that support it. The window to file is short, additional evidence is admitted only in defined circumstances, and written submissions must anticipate a Bench that decides largely on paper. Experienced representation delivers three decisive advantages:

Grounds that hold up. Grounds of appeal and statements of facts are drafted to withstand technical scrutiny — precise, supported by facts on record, and framed to give the appellate authority a clear basis to decide in your favour.
Evidence admitted correctly. Additional evidence not produced before the AO can only be admitted under Rule 46A in defined circumstances. We build the application so evidence is not rejected on a technicality before its merits are even considered.
Precedent-backed advocacy. Written submissions are supported by judicial precedents directly on point, distinguishing any adverse rulings the Assessing Officer may have relied upon.

How the Appeal Will Proceed

An appeal before the CIT(Appeals)/NFAC typically progresses through the following stages, each with its own timeline under the Act.

Stage	What It Involves
Filing of appeal (Form 35)	The appeal is filed electronically in Form 35 within 30 days of receipt of the assessment order, along with grounds of appeal, statement of facts and the order appealed against.
Grounds of appeal & statement of facts	We draft precise, legally grounded grounds of appeal, each addressing a specific addition or disallowance, supported by a clear statement of facts.
Written submissions	Detailed written submissions are prepared, supported by judicial precedents, reconciliations and documentary evidence, and filed in response to notices issued by the NFAC.
Additional evidence (Rule 46A)	Where relevant evidence could not be produced before the AO, we prepare an application under Rule 46A explaining the reason and seeking its admission.
Remand report	If the NFAC calls for a remand report from the AO on any additional evidence or fact, we prepare a rejoinder addressing the AO’s comments.
Hearing, where granted	Where a personal hearing is granted, we prepare for and represent you at the video-conference hearing before the appellate authority.
Appellate order	The CIT(A)/NFAC disposes of the appeal by a reasoned order, which may confirm, reduce, enhance or delete the additions.
Further appeal	If the order is adverse, a further appeal lies before the Income Tax Appellate Tribunal within 60 days of receipt of the order.

Scope of Work

A. Case Analysis & Strategy

Review the assessment order in detail to identify factual and legal infirmities in each addition or disallowance.
Assess the merits of each ground and prioritise those with the strongest chance of success.
Identify any procedural lapses in the assessment that can independently support the appeal.

B. Drafting & Documentation

Draft grounds of appeal, statement of facts and Form 35 for filing on the Portal within the limitation period.
Prepare written submissions supported by judicial precedents, computations and reconciliations.
Prepare Rule 46A applications for admission of additional evidence, where warranted.

C. Representation & Follow-up

Track notices and communications issued by the NFAC and respond within the timelines prescribed.
Prepare rejoinders to any remand report called for from the Assessing Officer.
Represent you at the hearing, where one is granted, and keep you informed at every stage until the order is passed.

If you have received an adverse assessment order, the appeal must generally be filed within 30 days — timely action protects your options.

Schedule a Consultation

← Back to Litigation Practice