Form 35 Grounds of Appeal Format — Statement of Facts for CIT(A) Appeal
STATEMENT OF FACTS AND GROUNDS OF APPEAL
[Annexures to Form No. 35 — Appeal to the Commissioner of Income-tax (Appeals) / Joint Commissioner (Appeals)]
Before the {{officer_designation}}
Appellant: {{client_name}}
PAN: {{client_pan}}
Address: {{client_address}}
Assessment Year: {{assessment_year}}
Order appealed against: Order under section {{order_section}} of the Income-tax Act, 1961 passed by the {{ao_designation}}, vide dated
Demand disputed: ₹ {{disputed_demand}}
PART A — STATEMENT OF FACTS
1. The appellant is ____________ [state constitution and nature of business / source of income in one or two sentences — e.g. 'a private limited company engaged in the trading of electrical goods'].
2. For the Assessment Year {{assessment_year}}, the appellant filed its return of income declaring total income of ₹ ____________. The chronology of the proceeding is set out below:
| Date | Event | Reference |
|---|
| ____________ | Return of income filed u/s 139(1) / 139(4) | Ack. no. ____________ |
| ____________ | Notice u/s 143(2) issued and served | ____________ |
| ____________ | Notice(s) u/s 142(1) — details called for and furnished | ____________ |
| ____________ | Show-cause notice on the proposed addition(s) | ____________ |
| Order u/s {{order_section}} passed; demand notice u/s 156 served | |
3. In the impugned order, the learned Assessing Officer made the following addition(s) / disallowance(s): ____________ [state each addition with the amount and the section invoked — one sentence per addition, no argument here].
4. The appellant duly furnished ____________ [list the key evidence filed during assessment — confirmations, ledger extracts, bank statements, valuation reports]. The addition has been made ____________ [state, factually, what the AO did or failed to do — e.g. 'without dealing with the evidence on record' / 'by treating the transaction as unexplained despite confirmations'].
5. Aggrieved by the said order, the appellant prefers the present appeal within the period of thirty days provided in section 249(2). The prescribed appeal fee under section 249(1) has been paid vide challan dated ____________.
- Drafting hint: the SoF is a neutral narrative — facts, dates, evidence filed. Save every argument for the grounds and written submissions.
- Drafting hint: keep the chronology table complete; NFAC decides on the record, and a clean chronology is the fastest way to show compliance at every stage.
PART B — GROUNDS OF APPEAL
1. On the facts and in the circumstances of the case and in law, the order passed by the learned Assessing Officer under section {{order_section}} is bad in law and void ab initio, ____________ [state the jurisdictional / procedural defect, if any — e.g. 'the notice u/s 143(2) not having been validly served'; omit this ground if none exists].
2. On the facts and in the circumstances of the case and in law, the learned Assessing Officer erred in making an addition of ₹ ____________ on account of ____________, without appreciating that ____________ [state the ground concisely — one addition per ground].
3. Without prejudice to Ground 2, the learned Assessing Officer erred in ____________ [alternative / quantum ground — e.g. 'adopting the gross receipts instead of the embedded profit element' or 'not allowing the corresponding deduction / telescoping benefit'].
4. On the facts and in the circumstances of the case and in law, the learned Assessing Officer erred in levying interest under sections 234A / 234B / 234C, which is consequential and excessive.
5. The appellant craves leave to add, alter, amend or withdraw any of the above grounds of appeal at or before the time of hearing.
- Drafting hint: one issue per ground. 'Without prejudice' grounds preserve the alternative argument without conceding the primary one — sequence them from the strongest legal ground to quantum alternatives.
- Drafting hint: grounds should be concise assertions of error, not argumentative essays — the reasoning goes in the written submissions filed during the NFAC hearing window.
PRAYER
The appellant prays that the addition(s) / disallowance(s) made in the impugned order be deleted, the consequential interest be recomputed, and such further relief be granted as the facts and circumstances of the case may warrant.
VERIFICATION
I, ____________, the appellant / authorised signatory of the appellant, do hereby declare that what is stated above is true to the best of my information and belief.
Place: __________________
Date: 31 July 2026
For {{client_name}}
_______________________________
Authorised Signatory
