Grounds before ITAT can be raised even if no cross objection filed before CIT(A)

Sanjay Sawhney Vs PCIT (Delhi High Court)

Conclusion: Rule 27 embodies a fundamental principal that a Respondent who may not have been aggrieved by the final order of the Lower Authority or the Court, and therefore, has not filed an appeal against the same, is entitled to defend such an order before the Appellate forum on all grounds, including the ground which has been held against him by the Lower Authority, though the final order is in its favour.

Held: Rule 27 embodies a fundamen

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