Chapter XX: Sections 246A to 255:Appellate Proceedings before CIT(Appeals) & ITAT
Judicial representation and petition drafting challenging arbitrary assessment orders, addition of unexplained credits under Section 68/69, Transfer Pricing adjustments, and faceless assessment demand notices.
Statutory Scope & ApplicabilityCorporate entities, partnership firms, and high-net-worth taxpayers aggrieved by orders passed by the National Faceless Assessment Centre (NFAC) or jurisdictional Assessing Officers.
Default Consequence & ExposureRecovery proceedings under Section 226(3) including bank account attachment; demand for 20% mandatory pre-deposit; irreversible fiscal liabilities.