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CA Final · Direct Tax Laws & International Taxation · Income Tax Authorities

During a hearing before an Income-tax Commissioner in Jaipur, Mr. Rathi gives a deliberately false statement. Under the Income-tax Act, 2025, how are proceedings before an income-tax authority treated?

Such proceedings are deemed judicial proceedings. Section 257(1) of the Income-tax Act, 2025 provides that any proceeding before an income-tax authority is judicial for the purposes of sections 229 and 267 and section 233 of the Bharatiya Nyaya Sanhita, 2023, regardless of any Board notification.

  1. AAs administrative proceedings with no judicial character
  2. BAs judicial proceedings for the purposes of section 233 of the Bharatiya Nyaya Sanhita, 2023, among othersCorrect
  3. CAs judicial proceedings only if the Board so notifies
  4. DAs judicial proceedings only when the Commissioner (Appeals) conducts them

Explanation

Section 257(1) deems any proceeding under the Act before an income-tax authority to be a judicial proceeding for sections 229 and 267 and for section 233 of the Bharatiya Nyaya Sanhita, 2023. No Board notification is required and it is not limited to appellate authorities.

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