Income Tax Disputes Before HCs Doubled In Value Over Past Four Financial Years: Govt Tells Rajya Sabha

A sharp escalation in the value of income tax disputes pending before High Courts has emerged from fresh data placed before Parliament, with the total disputed amount nearly doubling between FY 2020-21 and FY 2024-25. The figures were disclosed in a reply tabled in the Rajya Sabha by the Minister of State in the Ministry of Finance Pankaj Chaudhary, capturing year-wise pendency and amounts locked at each appellate stage.

The numbers paint a split-screen picture of India's tax dispute system. At the level of the First Appellate Authority (CIT(A)/JCIT(A)), the volume of appeals has risen only marginally over five years, from 4.48 lakh in 2020-21 to 5.39 lakh in 2024-25.

Yet the value of disputes has shrunk over time. The most dramatic reduction happened in a single year: from ₹24.5 lakh crore in FY 2020-21 to ₹14.18 lakh crore in FY 2021-22, a fall of nearly ₹10 lakh crore.

Subsequent years show the disputed amount stabilising around ₹16-17 lakh crore, indicating that while more appeals entered the system, their average value was considerably lower than earlier years. This divergence, higher caseload but lower financial stakes, suggests a shift in the composition of disputes at the first appellate stage.

The picture flips entirely at the High Court level. Pending appeals there increased from 31,971 in FY 2020-21 to 34,486 in FY 2024-25, but the value involved surged far more aggressively, from ₹2.75 lakh crore to ₹5.65 lakh crore over the same period. The amount locked before High Courts has therefore grown by more than 100 percent in just four years.

This upward swing signals that while fewer cases may be climbing to the High Court, those that do involve increasingly higher fiscal stakes.

Click here to read the answer by the Minister of State, Ministry of Finance, on data of year-wise number of Income Tax disputes in the last five years.