121  [Qualifications for appointment of Special Director (Appeals). 
A  person shall not be qualified for appointment as a Special Director (Appeals)  unless he— 
(a)  has been a member of the Indian Legal Service and has held a post in Grade I of  that Service; or 
(b)  has been a member of the Indian Revenue Service and has held a post equivalent  to a Joint Secretary to the Government of India.] 
  
Note: 
1.  	  Section  21 substituted by the Finance Act, 2017, w.e.f. 26-5-2017. Prior to its  substitution, said section read as under : 
"21.  Qualifications for appointment of Chairperson, Member and Special Director  (Appeals).— (1) A person shall not be qualified for appointment as the  Chairperson or a Member unless he— 
(a)  in the case of Chairperson, is or has been, or is qualified to be, a Judge of a  High Court; and 
(b)  in the case of a Member, is or has been, or is qualified to be, a District  Judge. 
(2)  A person shall not be qualified for appointment as a Special Director (Appeals)  unless he— 
(a)  has been a member of the Indian Legal Service and has held a post in Grade I of  that Service; or 
(b)  has been a member of the Indian Revenue Service and has held a post equivalent  to a Joint Secretary to the Government of India." 
  
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