The Government of india on December 09, 2025, laid on the table of the Rajya Sabha comprehensive data relating to income tax disputes across various appellate stages for the last five financial years. The information was provided in a written reply by Minister of State in the Ministry of Finance, Shri Pankaj Chaudhary, to an unstarred question on the subject of Income Tax Disputes.
Responding to queries regarding the year-wise number of disputes, the quantum of tax involved, and classification of disputes at different stages, the Minister stated that the Income Tax Department systematically maintains data for each appellate level.
Major Highlights
- First Appellate Authority
The number of income tax appeals pending before the First Appellate Authority [CIT(A)/JCIT(A)] shows marginal variation over five years.
- Pending appeals were 4,48,992 in FY 2020-21, increasing to 5,48,278 in FY 2023-24, before moderating to 5,39,863 in FY 2024-25.
- The disputed amounts ranged between ₹14.18 lakh crore and ₹24.52 lakh crore during the period.
- ITAT, High Courts and Supreme Court
The Ministry also provided year-wise pending appeals and the disputed tax amount for forums including the Income Tax Appellate Tribunal (ITAT), High Courts, and the Supreme Court of India.
For FY 2024-25, data indicates:
| Forum | Pending Appeals | Disputed Amount |
| ITAT | 22,960 | ₹3.64 lakh crore |
| High Courts | 34,486 | ₹5.65 lakh crore |
| Supreme Court | 6,338 | ₹25,403 crore |
Earlier FYs reflect varied patterns across fora, with pending appeals and tax amounts showing fluctuation rather than linear increase or decline.
Classification of Disputes
The Minister clarified that data on pending appeals and corresponding disputed amounts is recorded separately for each stage, namely:
- First Appellate Authority [CIT(A)/JCIT(A)]
- Income Tax Appellate Tribunal (ITAT)
- High Courts
- Supreme Court of India
Conclusion
The data presented reflects the scale and structured monitoring of income tax litigation across judicial tiers. The Ministry emphasized its continued efforts to streamline dispute resolution and reduce pendency levels through reforms such as faceless appeals, dispute resolution schemes, and expanded use of technology.
The reply can be accessed at: https://a2ztaxcorp.net/wp-content/uploads/2025/12/INCOME-TAX-DISPUTES.pdf
