A Commissioner imposes a penalty on Surya under section 439 of the Income-tax Act, 2025. What is the ordinary appellate forum and filing period?

Section 362(1)(b)(ii) of the Income-tax Act, 2025 gives an appeal to the Appellate Tribunal against a penalty order passed by a Principal Commissioner or Commissioner under section 439, and section 362(3) allows two months from the end of the month in which the order is communicated. The Commissioner (Appeals) hears appeals against orders of lower authorities such as the Assessing Officer, not against the Commissioner's own order.