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HIGHER AND SUBORDINATE AUTHORITIES AFTER RECENT AMENDEMENT -analysed to show that multiple designations are in practice. These need reduction and simplification to avoid litigation.

Date 07 Oct 2026
Income-tax authority hierarchy preserves assessment and appellate discretion while updated reporting relationships clarify first-appellate supervisory subordination.
Section 118 enables the Board to establish administrative subordination among income-tax authorities based on functional jurisdiction, territorial jurisdiction and assigned work. The hierarchy runs from the Central Board of Direct Taxes through principal, director, commissioner, deputy, assistant, officer, recovery and inspector levels. The amended appellate arrangement places Joint Commissioners (Appeals) and Additional Commissioners (Appeals) under Principal Chief Commissioners and Chief Commissioners. Administrative control cannot dictate a particular assessment or case disposal and must preserve the discretion of first appellate authorities. (AI Summary)

Income Tax authorities are specified under section 116 and their control is exercised by CBDT vide S. 118 as per following provisions:

116. There shall be the following classes of income-tax authori ties for the purposes of this Act, namely :-

(a) the Central Board of Direct Taxes constituted under the Central Boards of Revenue Act, 1963 (54 of 1963),

(aa) Principal Directors General of Income-tax or Principal Chief Commissioners of Income-tax,]

(b) Directors-General of Income-tax or Chief Commissioners of Income-tax,

(ba) Principal Directors of Income-tax or Principal Commissioners of Income-tax,]

(c) Directors of Income-tax or Commissioners of Income-tax or Commissioners of Income-tax (Appeals),

(cc) Additional Directors of Income-tax or Additional Commissioners of Income-tax or Additional Commissioners of Income-tax (Appeals),]

(cca) Joint Directors of Income-tax or Joint Commissioners of Income-tax or Joint Commissioners of Income-tax (Appeals),

(d) Deputy Directors of Income-tax or Deputy Commissioners of Income-tax or Deputy Commissioners of Income-tax (Appeals),

(e) Assistant Directors of Income-tax or Assistant Commis sioners of Income-tax,

(f) Income-tax Officers,

(g) Tax Recovery Officers,

(h) Inspectors of Income-tax.

Control of income-tax authorities.

118. The Board may, by notification in the Official Gazette, direct that any income-tax authority or authorities specified in the notification shall be subordinate to such other income-tax authority or authorities as may be specified in such notification.

From the updated notification:

REMARKS- simple words or abbreviations of posts commonly known

CENTRAL BOARD OF DIRECT TAXES

NOTIFICATION NO. 7816 New Delhi, the 30th March, 1988

(INCOME-TAX) after recent amendment vide Notification no. 133/2026 Dated 30th September, 2026

 

CBDT acts under supervision and control of Central Government of India under Finance Ministry.

S.O. 359(E) - In exercise of the powers conferred by section 118 of the Income-tax Act, 1961 (43 of 1961), the Central Board of Direct Taxes hereby directs that-

CBDT has issued notification and amending Notifications from time to time.

(a) Principal Directors General), Principal Chief Commissioners, Directors General of Income-tax (Investigation), Chief Commissioners of Income-tax (Central), Director General of Income-tax (I and CI) and Chief Commissioner of Income-tax (Exemptions) shall be subordinate to the Central Board of Direct Taxes;

 

Subordinates of CBDT are:

PDG of IT,

PCCIT

DGIT(Inv.)

CCIT (Central)

DGIT(I and CI)

CCIT(E)

 

(aa) Directors General or Chief Commissioners shall be subordinate to the Principal Director Generals or Principal Chief Commissioners within whose jurisdiction they perform their functions;]

 

Subordinates of

PDGIT or PCCIT are:

DGIT

CCIT

(b) Principal Directors or Directors or Principal Commissioners or Commissioners or Commissioners (Appeals) shall be subordinate to the Principal Directors General or Directors General or Principal Chief Commissioners or Chief Commissioners within whose jurisdiction they perform their functions;]

 

Subordinates of

(PDGIT or

DGIT or

PCCIT

CCIT):

PDIT

DIT

PCIT

CIT

CIT(A)

 

[(ba) Joint Commissioners of Income-tax (Appeals) or Additional Commissioners of Income-tax (Appeals) shall be subordinate to the Principal Chief Commissioners of Income-tax or Chief Commissioners of Income-tax within whose jurisdiction they perform their functions.]

 

Subordinates of:

PCCIT

CCIT are:

JCIT (A)

ADDl.CIT(A)

(c) Additional Directors or Additional Commissioners or Joint Directors or Joint Commissioners of Income-tax shall be subordinate to the Directors or Commissioners of Income-tax within whose jurisdiction they perform their functions or other income-tax authority under whom they are appointed to work and to any other income-tax authority to whom the Director or the Commissioner of the Income-tax, as the case may be, or other income-tax authority is subordinate;

Subordinates of

DIT or

CIT will be:

 

Addl Director IT

Addl Commissioner IT

Joint Commissioner IT

 

(d) Assistant Directors or Assistant Commissioners shall be subordinate to the Deputy Directors or Deputy Commissioners within whose jurisdiction they perform their functions or other income-tax authority under whom they are appointed to work and to any other income-tax authority to whom the Deputy Director or the Deputy Commissioner, as the case may be, or other income-tax authority is subordinate;

 

Sub-ordinate of

(DDIT or

DCIT or

Or Other IT authority under whom appointed or who is superior to DDIT or DCIT) Are:

AD IT

AC IT

(e) Income-tax Officers shall, be subordinate to the Assistant Directors or Assistant Commissioners within whose jurisdiction they perform their functions or other income-tax authority under whom they are appointed to work and to any other income-tax authority to whom the Assistant, Director or the Assistant Commissioner, as the case may be, or other income-tax authority is subordinate.

 

Subordinate of

(ADIT or

ACIT or

Or Other IT authority under whom appointed or who is superior to ADIT or ACIT), are:

 

ITO

(f) Tax Recovery Officers shall be subordinate to the Assistant Directors or Assistant Commissioners or other income-tax authority under whom they are appointed to work and to any other income-tax authority to whom the Assistant Director or the Assistant Commissioner, as the case may be, or other income-tax authority is subordinate;

Subordinate to

(ADIT,

ACIT

Other IT authority under whom appointed or superior to ADIT, ACIT)

Are:

TRO

(g) Inspectors of Income-tax shall be subordinate to the Income-tax Officers or any other income-tax authority under whom they are appointed to work and to any other income-tax authority to whom the said office or other income-tax authority is subordinate;

 

Subordinate of (ITO or

other authority under whom appointed to work and to whom ITO is subordinate), are:

 

IIT Inspector of IT

 

Provided that nothing in this notification shall have the effect of-

(a) requiring any income-tax authority to make a particular assessment or to dispose of a particular case in a particular manner; or

(b) interfering with the discretion of the Commissioner of Income-tax (Appeals) or Additional Commissioners of Income-tax (Appeals) or Joint Commissioners of Income-tax (Appeals).

Vide note to the notification

 

Note : Directors General of Income-tax (Investigation), Chief Commissioners of Income-tax (Central) and Director General of Income-tax (I and CI) and Chief Commissioner of Income-tax (Exemption) shall report to the Principal Chief Commissioner of Income-tax of the respective territorial areas or region for personnel and vigilance matters.

 

Report will be given to PCIT of respective territorial area or region for personnel and vigilance matters by:

DGIT (Inv),

CCIT (Central)

DGIT(I and CI)

CCIT ( E ).

 

This note is for intended collection of reports from concerned authorities.

 

2. This notification shall come into force on and from the 1st day of April, 1988.

[F. No. 187/5/88-IT.A-I]

In the table given above any authority either senior or junior will be related to geographical area or other jurisdictional classification for which appointment is made.

The expression like or any other authority under which appointed means other authority under which a junior authority is appointed to work. For example, certain ACIT, ITO and inspectors are generally appointed to work under various senior authorities.

Independence and discretion is intended to be maintained: By the proviso (a) in the notification it is intended /provided to preserve independence and discretion of authorities to make assessment orders or dispose of case and senior authority will not dictate to make any order or dispose of any case in a particular manner. And by the proviso (b) any interference of senior authority in the discretion of first appellate authorities is intended. Just amended clause in above table is analysed further below:

After Amendment on 30.09.2026

Before Amendment

 

(ba) Joint Commissioners of Income-tax (Appeals) or Additional Commissioners of Income-tax (Appeals) shall be subordinate to the Principal Chief Commissioners of Income-tax or Chief Commissioners of Income-tax within whose jurisdiction they perform their functions.

[(ba) Joint Commissioners of Income-tax (Appeals) or Additional Commissioners of Income-tax (Appeals) shall be subordinate to the Chief Commissioners of Income-tax within whose jurisdiction they perform their functions;]"

Words inserted are:

Principal Chief Commissioners of Income-tax or

Substituted vide Notification No. 133/2026 dated 30-09-2026 w.e.f. 30-09-2026 before it was read as- see next column

 

 

Multiple designations:

As noted above there are multiple designations of senior authorities and multiple designations of subordinate authorities.

In the Notification in many posts Income-tax, is not added, whereas as per section 116 it is mentioned against designations of authorities.

Organization Tree

[ C B D T ]

[ Pr. CCIT ] [ Pr. DGIT ]

(Appellate Vertical) (Administrative Vertical) (Investigation Vertical) (Other Spec. Wings)

Clause (b): Clause (b): Clause (a): Clause (a):

CIT (A) Pr. CIT DGIT (Inv) CCIT (Cent)

CIT DGIT (I&CI)

Pr. DIT CCIT (E)

DIT

Clause (ba): Clause (aa):

Addl.CIT(A) Clause (c): DGIT

JCIT (A) Addl. CIT

JCIT

[Reports ONLY Addl. DIT

to Pr.CCIT/ JDIT

CCIT] DI (Inv)

Clause (d):

DCIT / DIT [Note: DGs/CCITs of specialized wings report to

ACIT / AIT territorial Pr. CCIT for Personnel/Vigilance]

Clause (e): Clause (f):

ITO [AO] TRO

Clause (g):

ITI

 

Abbreviations used

  • CBDT: Central Board of Direct Taxes
  • Pr. CCIT / CCIT: Principal Chief Commissioner / Chief Commissioner of Income Tax
  • Pr. DGIT / DGIT: Principal Director General / Director General of Income Tax
  • CIT(A) / Addl. CIT(A) / JCIT(A): Commissioner / Additional Commissioner / Joint Commissioner of Income Tax (Appeals) being first appellate authorities.
  • Pr. CIT / CIT: Principal Commissioner / Commissioner of Income Tax
  • Pr. DIT / DIT: Principal Director / Director of Income Tax
  • Addl. CIT / JCIT: Additional Commissioner / Joint Commissioner of Income Tax
  • Addl. DIT / JDIT: Additional Director / Joint Director of Income Tax
  • DCIT / ACIT: Deputy Commissioner / Assistant Commissioner of Income Tax
  • DDIT / ADIT: Deputy Director / Assistant Director of Income Tax
  • ITO [AO]: Income Tax Officer [Assessing Officer]
  • TRO: Tax Recovery Officer
  • ITI: Income Tax Inspector
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