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of <h1>Income Tax Bill 2025 Clause 360 maintains appellate powers identical to Section 251 with modernized language</h1> The Income Tax Bill 2025's Clause 360 and the Income-tax Act 1961's Section 251 both govern appellate powers of Commissioners and Joint Commissioners in tax matters. Both provisions empower appellate authorities to confirm, reduce, enhance, or annul assessments and penalty orders. Key powers include setting aside assessments for fresh consideration (limited to Commissioners), considering Settlement Commission materials when proceedings abate, and addressing any matters arising from proceedings. Both require reasonable opportunity of hearing before enhancement or reduction, upholding natural justice principles. The 2025 Bill modernizes language while maintaining substantive parity with existing law.
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