High Court Appeals under Indian Income Tax Law : Clause 365 of the Income Tax Bill, 2025 Vs. Section 260A of the Income-tax Act, 1961

Substantial question of law: High Court appeals limited to legal issues, streamlining tax appellate review and implementation.

Clause 365 permits appeals to the High Court from Appellate Tribunal orders only when the High Court is satisfied a substantial question of law arises; it prescribes eligible appellants, a time-limited memorandum-based filing, condonation for sufficient cause, High Court formulation and limitation of the question(s) heard (with power to add questions for recorded reasons), reasoned judgments with costs, authority to decide issues not determined or wrongly decided by the Tribunal, application of Civil Procedure rules, and an express duty on the Assessing Officer to give effect to the High Court's judgment.