Chapter XVIII of the Income-tax Act, 2025 runs from section 356 to section 389 and covers appeals, revisions and alternate dispute resolutions. Its 34 sections replace 36 sections of the Income-tax Act, 1961. This guide gives the complete section-by-section mapping between the two Acts.
What Chapter XVIII covers
Chapter XVIII is the dispute chapter: appeals to the Joint Commissioner (Appeals) and Commissioner (Appeals), the Tribunal, the High Court and the Supreme Court, plus revision and the alternate dispute resolution routes.
Chapter XVIII contains 34 sections (sections 356 to 389). Between them they carry forward the substance of 36 sections of the Income-tax Act, 1961.
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 changed in Chapter XVIII
- Section 357 is the first appeal — appealable orders before the Commissioner (Appeals), replacing section 246A. Section 356 covers the Joint Commissioner (Appeals) route (old section 246).
- Section 358 is the form and limitation for filing an appeal (old section 249) and section 360 carries the appellate powers (old section 251).
- Tribunal appeals are section 362 (old 253), High Court appeals section 365 (old 260A) and Supreme Court appeals section 367 (old 261).
- Revision splits cleanly: section 377 for orders prejudicial to revenue (old 263) and section 378 for other orders (old 264).
- Advance rulings are sections 380 to 389, carrying the 245N to 245W series, and the Dispute Resolution Committee is section 379.
Chapter XVIII: complete section mapping (2025 → 1961)
Every section of Chapter XVIII is listed below with the section or sections of the Income-tax Act, 1961 that it corresponds to. Where a section is marked as read with a Schedule, the operative detail sits in that Schedule rather than in the section itself.
| 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 |
| 369 | Tax to be paid irrespective of appeal, etc | 265 |
| 370 | Execution for costs awarded by Supreme Court | 266 |
| 371 | Amendment of assessment on appeal | 267 |
| 372 | Exclusion of time taken for copy | 268 |
| 373 | Filing of appeal by income-tax authority | 268A |
| 374 | Interpretation of “High Court” | 269 |
| 375 | Procedure when assessee claims identical question of law is pending before High Court or Supreme Court | 158A |
| 376 | Procedure where an identical question of law is pending before High Courts or Supreme Court | 158AB |
| 377 | Revision of orders prejudicial to revenue | 263 |
| 378 | Revision of other orders | 264 |
| 379 | Dispute Resolution Committee in certain cases | 245MA, 502 |
| 380 | Interpretation | 245N |
| 381 | Board for Advance Rulings | 245-OB |
| 382 | Vacancies, etc., not to invalidate proceedings | 245P |
| 383 | Application for advance ruling | 245Q |
| 384 | Procedure on receipt of application | 245R |
| 385 | Appellate authority not to proceed in certain cases | 245RR |
| 386 | Advance ruling to be void in certain circumstances | 245T |
| 387 | Powers of the Board for Advance Rulings | 245U |
| 388 | Procedure of Board for Advance Rulings | 245V |
| 389 | Appeal | 245W |
How to use this mapping
- Working on a year up to 2025-26? Use the 1961 section in the right-hand column. The old Act governs those years under section 536.
- Working on tax year 2026-27 onwards? Use the new section number in the left-hand column, and read the section text rather than assuming the old provision was copied verbatim.
- Drafting a reply or an appeal? Cite the section that applies to the year in dispute, not the section in force when you are writing.
- Updating templates and software? Sections that merged — shown where one new section maps to several old ones — need the most attention, because a single new provision now carries what were separate conditions.
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.