Clarification in respect of filing of appeal before the Appellate Tribunal.

Appellate time limit paused until Appellate Tribunal President assumes office, permitting declarations to defer recovery and preserve appeals.

Clarification states that where the Appellate Tribunal is not yet constituted, the statutory three month appeal period runs from the later of communication of the order or the date the Appellate Tribunal President enters office. Appellate Authorities should note this in orders and dispose pending appeals. For recovery after an adverse appellate order, taxpayers may submit a prescribed declaration to the arrear recovery wing indicating intention to file an appeal, thereby informing recovery authorities pending Tribunal constitution.