Appeal Memo to ITAT (Form 36) — Drafting Guide and Template

FORM No. 36
[See rule 47(1) of the Income-tax Rules, 1962]
Form of appeal to the Appellate Tribunal

IN THE INCOME TAX APPELLATE TRIBUNAL, [___] BENCH, [City]

1.  Appellant                 : [Name]
2.  PAN / TAN                 : [ABCDE1234F]
3.  Assessment Year           : [2024-25]
4.  Order appealed against    : Order u/s 250 dated [date] passed by
    the CIT(A) / NFAC, [DIN ____]
5.  Date of communication     : [date order served]
6.  Address for service of
    notices on Appellant       : [full address / email]
7.  Address for service on
    Respondent                 : The ACIT/ITO, [Ward/Circle], [City]
8.  Respondent                : The [Assessing Officer], [Circle]
9.  Relief claimed in appeal  : Deletion of additions of ₹[______] and
    consequential relief in tax and interest (see grounds below).

GROUNDS OF APPEAL

1. That on the facts and in the circumstances of the case and in law,
   the learned CIT(A) erred in confirming the addition of ₹[______]
   made by the AO u/s 68 of the Income-tax Act, 1961, ignoring the
   confirmations, PAN and bank statements filed by the appellant.

2. That the learned CIT(A) erred in upholding the disallowance of
   ₹[______] u/s 40(a)(ia) even though TDS was deposited before the
   due date of filing the return u/s 139(1).

3. That the learned CIT(A) erred in sustaining the disallowance of
   ₹[______] u/s 14A r.w. Rule 8D in excess of the exempt income
   actually earned of ₹[______].

4. That the learned CIT(A) erred in confirming the levy of interest
   u/s 234A/234B/234C and in not directing the AO to drop penalty
   proceedings u/s 270A.

5. That the appellant craves leave to add, amend, alter or withdraw
   any of the above grounds before or at the time of hearing.

VERIFICATION
I, [Name], son/daughter of [__], the appellant, do hereby declare that
what is stated above is true to the best of my information and belief.

Verified today the [___] day of [Month, Year] at [City].

Signature of Appellant: ______________
[Name / Designation]

Documents enclosed:
  1. Form 36 (in triplicate)  — this memorandum
  2. Two copies of the order u/s 250 appealed against
  3. Two copies of the assessment order u/s 143(3)/147
  4. Two copies of the grounds of appeal filed before CIT(A) (Form 35)
  5. Copy of challan for the appeal fee (Tribunal fee)
  6. Statement of facts / paper book (to be filed separately)