Section 369
Section 369: tax to be paid irrespective of appeal
Section 369 is a short but important rule: filing an appeal to the High Court or Supreme Court does not, by itself, suspend the obligation to pay tax as per the assessment already made.
The rule
Irrespective of the fact that an appeal has been preferred to the High Court or the Supreme Court, tax remains payable as per the assessment made in the case.
Frequently asked questions
Does filing an appeal to the High Court or Supreme Court stop tax demand recovery?
No - Section 369 makes clear that tax stays payable as per the assessment made in the case, regardless of a pending appeal to the High Court or Supreme Court.
Related sections
Want this applied to your actual filing, not just explained?
Get help managing tax demand during an appealLast updated 9 September 2026