From the desk of; Navneet Shukla

The Ministry of Law and Justice has notified amendments to the Income-tax (Appellate Tribunal) Rules, 1963, making the use of digital signatures mandatory for filing appeals before the Income Tax Appellate Tribunal (ITAT). The changes have been brought into force through the Income-tax (Appellate Tribunal) Amendment Rules, 2025, which came into effect upon publication in the Official Gazette.

Under the amended framework, appeals before the ITAT are now required to be filed electronically. Rule 6 of the principal rules has been substituted to provide that a memorandum of appeal shall be filed by the appellant or an authorised agent “under his digital signature.” With this substitution, the long-standing practice of physical filing of appeals in duplicate or triplicate has been discontinued. Appeals, accompanying documents and paper books can now be filed in a single copy through the electronic mode.

The amendments also formally recognise digital identifiers as essential particulars of parties before the Tribunal. Definitions of “digital signature,” “e-mail address,” and “mobile number” have been inserted into the rules. These details will now be treated as official contact information for the purpose of service of notices, communications and orders by the Tribunal.

The scope of documents required to accompany an appeal has also been clarified. In appeals arising out of directions issued by the Dispute Resolution Panel, appellants are now required to file copies of the draft assessment order, the Transfer Pricing Officer’s order, objections filed before the Panel and the directions issued by the Panel. In cases where an appeal is filed against an order passed by senior tax authorities such as the Principal Chief Commissioner, Chief Commissioner or Commissioner, a copy of the impugned order must be enclosed with the memorandum of appeal.

To avoid disputes regarding service of notices, the amended rules introduce a revised memorandum of appeal mechanism. Where there is any change in the address, e-mail address, mobile number or telephone number of a party, the appellant is required to file a revised memorandum of appeal reflecting such changes. The Tribunal will continue to use the earlier details on record unless a revised memorandum is filed in accordance with the prescribed procedure.

The amendments also tighten procedural disclosures in miscellaneous applications. Any person filing a miscellaneous application is now required to clearly disclose whether a similar application had been filed earlier against the same order, along with the status of such application. Copies of orders passed on earlier miscellaneous applications must also be placed on record.

Stay applications have also been brought within the digital filing framework. The amended rules provide that stay applications shall be filed in the same manner and following the same procedure as appeals, effectively doing away with physical filing of stay petitions.

In addition, the language of the rules has been updated to reflect current digital practices. References to “xerox” copies have been replaced with “photocopy,” and provisions linked to physical submission of documents in multiple copies have been omitted, reinforcing the Tribunal’s transition to a fully electronic filing system. With these amendments, the ITAT’s procedural rules have been aligned with the digital ecosystem already adopted by other tax authorities and courts. The move is expected to streamline filings, reduce paper-based compliance and improve efficiency in appellate proceedings before the Tribunal.