A party who has not appealed cannot be permitted to raise a ground

Brief of the Case: In the case of CIT vs Divine Infracon Pvt. Ltd , Delhi High Court reiterated its own order in case of CIT vs. Edward Keventer (Successors) Pvt. Ltd that it would not be open to a respondent to travel outside the scope of the subject matter of the appeal under the guise of invoking Rule 27 of the Income Tax (Appellate Tribunal) Rules, 1963. Facts of the Case: The Assessee filed a return for the A.Y. 2008-09 declaring a total income of Rs.3,84,027/- on 30 September, 2009. Thereafter, on 14 September, 2010 search and seizure operations were conducted at the registered office o...