March15,2019

According to the review form the Central Board of Direct Taxes (CBDT), there were over 90,000 tax cases pending at the stage of Income Tax Appellate Tribunal (ITAT), which was about Rs 2.01 lakh crore quarrelsome requirements at the end of March 2017, motivating the officials with the standard of reasonable appeals.

During the traditional tax litigation, the appealer would process the action with the tax commissioners, ITAT, High Court and Supreme Court if necessary. ITAT is the last fact-finding administration. In accordance with the statistics from the 2018 Economic Survey, 85% of the appeals were filed by ITAT. Nonetheless, the success-rating of the appeals from ITAT was less than 30%, which might be the performance-related goal that the ITAT officials need to accomplish. 

As a consequence, the CBDT indicated that the high success-rating of the appeals were emboldened. It could also make clear of the antagonistic cases. On the other hand, the alternative way was to bring in the private rulings form exalted ITAT officials or the third-party arbitration.