If you file appeals, this is the mapping you will use most. The first appeal moves from section 246A to section 357, and the Tribunal appeal from section 253 to section 362.
Quick answer: the mapping
| Income-tax Act, 1961 | Subject | Income-tax Act, 2025 |
|---|---|---|
| 246 | Appeal to Joint Commissioner (Appeals) | 356 |
| 246A | Appeal to Commissioner (Appeals) | 357 |
| 249 | Form of appeal and limitation | 358 |
| 250 | Procedure in appeal | 359 |
| 251 | Powers of the appellate authority | 360 |
| 253 | Appeal to the Tribunal | 362 |
| 254 | Orders of the Tribunal | 363 |
| 260A | Appeal to High Court | 365 |
| 261 | Appeal to Supreme Court | 367 |
| 263 | Revision prejudicial to revenue | 377 |
| 264 | Revision of other orders | 378 |
The Income-tax Act, 2025 received Presidential assent on 21 August 2025 and takes effect from 1 April 2026. The Income-tax Act, 1961 continues to govern every tax year up to 31 March 2026, and all assessments, appeals, penalties and prosecutions relating to those years are completed under the old Act by virtue of the repeal and savings provision in section 536. The mapping on this page is drawn from the section-wise concordance published with the Act, including the corrigenda notified in the Gazette on 3 September 2025.
What the 1961 provision did
Section 246A of the Income-tax Act, 1961 listed the orders appealable to the Commissioner (Appeals), section 249 prescribed the form and limitation, section 250 the procedure and section 251 the powers. Section 253 covered Tribunal appeals, section 260A High Court appeals and section 261 Supreme Court appeals.
Where it sits in the Income-tax Act, 2025
Chapter XVIII of the Income-tax Act, 2025 carries the whole appellate structure in sections 356 to 389, including revision in sections 377 and 378 and the alternate dispute resolution routes in sections 379 to 389.
What actually changed
- The hierarchy is preserved in order: 246 → 356, 246A → 357, 249 → 358, 250 → 359, 251 → 360, 252 → 361, 253 → 362, 254 → 363, 255 → 364, 260A → 365, 260B → 366, 261 → 367 and 262 → 368.
- Revision splits into two clear sections: section 377 for revision prejudicial to revenue (old 263) and section 378 for revision of other orders on the assessee's application (old 264).
- Advance rulings run from sections 380 to 389, carrying the 245N to 245W series, with the Dispute Resolution Committee in section 379.
- Repetitive appeal provisions carry over as sections 375 and 376 (old sections 158A and 158AB).
What to do about it
- Appeal memos, Form 35 equivalents and vakalatnama references should cite the section applicable to the year under appeal.
- An appeal against an assessment made under section 270 lies to the Commissioner (Appeals) under section 357.
- Check the limitation in section 358 for new-Act appeals and section 249 for old-Act appeals.
The sections around it in the new Act
Renumbering is easier to absorb in context. The table below lists the neighbouring provisions of the Income-tax Act, 2025 with the 1961 sections each of them carries forward, so you can see where this provision sits and what moved with it.
| New section (2025) | Provision | Corresponding 1961 section(s) |
|---|---|---|
| 356 | Appealable orders before Joint Commissioner (Appeals) | 246 |
| 357 | Appealable orders before Commissioner (Appeals) | 246A |
| 358 | Form of appeal and limitation | 249 |
| 359 | Procedure in appeal | 250 |
| 360 | Powers of Joint Commissioner (Appeals) or Commissioner (Appeals) | 251 |
| 361 | Appellate Tribunal | 252, 252A |
| 362 | Appeals to Appellate Tribunal | 253 |
| 363 | Orders of Appellate Tribunal | 254 |
| 364 | Procedure of Appellate Tribunal | 255 |
| 365 | Appeal to High Court | 260A |
| 366 | Case before High Court to be heard by not less than two Judges | 260B |
| 367 | Appeal to Supreme Court | 261 |
| 368 | Hearing before Supreme Court | 262 |
How to read a section mapping
- A corresponding section is not always an identical section. Where several 1961 sections map to one new section, conditions that used to sit apart are now read together.
- Where one 1961 section maps to several new sections, the old provision was split, and each new section carries only part of what you used to cite.
- Some new sections have no 1961 equivalent at all — the registered non-profit code in sections 332 to 355 is the largest example.
- Always cite by year. The Act that applies is decided by the tax year in question, not by the date you are writing on.
This page is a structural mapping guide, not tax advice. A corresponding section is not always an identical section — several provisions were merged, split or re-worded when they were carried over. Always read the actual text of the new section before relying on it, and check for later amendments, rules and CBDT notifications.