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“cross objection”

AppealsSection 253(4)Section 253(4)4,331 judgments

The decision most relied on for cross objection is Sanjay Sawhney v. Principal Commissioner of Income-tax (116 Taxmann.com 701), cited in 87 judgments on BharatTax.

Leading authorities on cross objection

Sanjay Sawhney v. Principal Commissioner of Income-tax
116 Taxmann.com 701 · 2020 · High Court
87
citing judgments

Rule 27 of the ITAT Rules allows a respondent to defend a favourable order of the CIT(A) by raising grounds decided against them, even without filing an appeal or cross-objection. Such issues can be raised orally and for the first time before the Tribunal.

DCIT v. Turquoise Investment & Finance Ltd.
378 ITR 693 · 2015 · High Court
68
citing judgments

An appellate authority can admit additional grounds of appeal, especially when they are legal in nature, and allows for filing cross-objections before the Tribunal where facts are on record.

Pr. CIT v. Sun Pharmaceuticals Industries Ltd.
86 Taxmann.com 148 · 2017 · High Court
54
citing judgments

A respondent in an appeal before the Tribunal can support the order appealed against on any grounds decided against them, even without filing a cross-objection, under Rule 27 of the Income Tax Appellate Tribunal Rules.

Peter Vaz v. Commissioner of Income Tax, Central Circle, Bangalore
128 Taxmann.com 180 · 2021 · High Court
34
citing judgments

An assessee can raise an objection regarding the validity of the Assessing Officer's jurisdiction for reopening a concluded assessment even if the issue was not raised before the CIT(Appeals), by invoking Rule 27 of the Income Tax Appellate Tribunal Rules, 1963. This is permissible if the issue is ancillary to the main issue and does not require additional evidence.

Dahod Sahakari Kharid Vechan Sangh Ltd. v. CIT
282 ITR 321 · 2006 · High Court
31
citing judgments

An assessee-respondent can support an appellate order on any ground available to them, even if they haven't filed cross-objections, provided the new ground is a point of law and doesn't require fresh evidence.

Mavany Brothers v. CIT, Panjim
62 Taxmann.com 50 · 2015 · High Court
25
citing judgments

A delay in filing cross-objections can be condoned if there are bonafide reasons and no mala-fide conduct or lackadaisical approach by the assessee.

CIT v. New India Assurance Company Ltd.
234 ITR 663 · 1998 · High Court
23
citing judgments

A cross objection filed by an assessee against an order of the CIT(A) can be considered as an appeal by the assessee.

CIT(E) v. Jamiatul Banaat Tankaria
168 Taxmann.com 35 · 2024 · High Court
20
citing judgments

The Commissioner of Income-tax (Exemptions) cannot invoke Section 13(1)(b) at the stage of granting registration under Section 12AB, especially when the assessee has a valid registration. Section 13(1)(b) is only attracted after the assessee has crossed the hurdle of being eligible for exemption under Section 11 by obtaining registration.

Judgments citing cross objection

Deputy Commissioner of Income Tax, Rohtak Circle vs. Ravi Prakash Aggarwal, Delhi

In the result, the cross objection filed by the assessee stands allowed

ITA 776/DEL/2024[2013]Status: DisposedITAT Delhi17 Nov 2025

Bench: Shri Satbeer Singh Godara & Shri S.Rifaur Rahmandcit, Rohtak Circle, Vs. Ravi Prakash Aggarwal, Rohtak. C/O M/S. R.P. Jewellers, 1186, 1St Floor, Kucha Mahajani, Chandni Chowk, Delhi – 110 006. (Pan : Adapa3506E) Co No.250/Del/025 (In Ita No.776/Del/2024) (Assessment Year: 2013-14) Ravi Prakash Aggarwal, Vs. Dcit, Rohtak Circle, C/O M/S. R.P. Jewellers, Rohtak. 1186, 1St Floor, Kucha Mahajani, Chandni Chowk, Delhi – 110 006. (Pan : Adapa3506E) (Appellant) (Respondent) Assessee By : Shri Gurbaksh Dang, Advocate Shri Bharat Bhushan, Advocate Revenue By : Shri Jitender Singh, Cit Dr Date Of Hearing : 17.11.2025 Date Of Order : 17.11.2025 O R D E R

For Appellant: Shri Gurbaksh Dang, AdvocateFor Respondent: Shri Jitender Singh, CIT DR
Section 148Section 149

Order : 17.11.2025 O R D E R PER S. RIFAUR RAHMAN, ACCOUNTANT MEMBER : 2 CO No.250/Del/2025 1. This appeal filed by the Revenue and Cross Objections by the Assessee are directed against the order dated 21.12.2023 passed by the Ld. Commissioner of Income-tax (Appeals)/National Faceless Appeal Centre (NFAC ... Delhi for the assessment year 2013-14. 2. Since the appeal and Cross Objection are inter-connected, hence, the same were heard together and disposed of by this common order for the sake of convenience. 3. At the time of hearing, ld. AR of the assessee submitted that assessee

DCIT Central Circle- 14, Delhi vs. Anuj Nagpal, New Delhi

In the result, the cross objections being CO No

ITA 1761/DEL/2022[2018-19]Status: DisposedITAT Delhi17 Nov 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmandcit, Central Circle 14, Vs. Anuj Nagpal, B-64, 1St Floor, New Delhi. Greater Kailash Part 1, New Delhi – 110 048. (Pan : Ackpn0439N) Co No.03/Del/2024 (In Ita No.1761/Del/2022) (Assessment Year: 2018-19) Anuj Nagpal, Vs. Dcit, Central Circle 14, B-64, 1St Floor, New Delhi. Greater Kailash Part 1, New Delhi – 110 048. (Pan : Ackpn0439N) (Appellant) (Respondent) Assessee By : Shri Akash Ojha, Advocate Revenue By : Shri Jitender Singh, Cit Dr Date Of Hearing : 17.11.2025 Date Of Order : 17.11.2025 O R D E R Per S. Rifaur Rahman: 1. The Revenue Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-31, New Delhi [“Ld. Cit(A)”, For Short] Dated 12.05.2022 For The Assessment Year 2018-19. The Assessee

For Appellant: Shri Akash Ojha, AdvocateFor Respondent: Shri Jitender Singh, CIT DR
Section 153ASection 153D

Delhi [“Ld. CIT(A)”, for short] dated 12.05.2022 for the Assessment Year 2018-19. The assessee 2 CO No.03/Del/2024 has also filed cross objections in the impugned order dated 12.05.2022 for the AY 2018-19. 2. At the outset of the hearing, ld. AR for the assessee submitted that that ... 285/2024 (Del), dated 15.05.2024 and submitted that by following the ratio of the aforesaid case laws, the legal issue involved in the instant cross objections may be allowed. 8. Per contra, ld. DR of the Revenue relied upon the orders of the authorities below and objected to the submissions

Income Tax Officer, Kakinada vs. Three Seasons Ware Housing, Rajeswari Nagar

ITA 554/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam14 Nov 2025AY 2018-19

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No. 554/Viz/2025 (िनधा"रण वष"/Assessment Year: 2018-19) Income Tax Officer, Vs. Three Seasons Ware Ward-1, Housing, Kakinada. Kakinada. Pan: Aajft4738R (Appellant) (Respondent) C.O. No. 41/Viz/2025 (In आ.अपी.सं /Ita No.554/Viz/2025 (िनधा"रण वष"/Assessment Year: 2018-19) Vs. Income Tax Officer, Three Seasons Ware Ward-1, Housing, Kakinada. Kakinada. Pan: Aajft4738R (Cross Objector) (Respondent) िनधा""रती "ारा/Assessee By: Shri Gvn Hari, Advocate (Hybrid Hearing) राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 11/11/2025 घोषणा की तारीख/Date Of 14/11/2025 Pronouncement: Co No.41/Viz/2025 Ito Vs. Three Seasons Ware Housing

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 143(2)Section 143(3)Section 260ASection 271ASection 68

ground that the appeal filed in the quantum proceedings was allowed by the Hon’ble ITAT, Visakhapatnam Bench. 2. Any other grounds of Cross Objection that may be raised at the time of hearing.” 3. Succinctly stated, the assessee firm had filed its return of income ... impugned addition. 14. Resultantly, we uphold the order passed by the CIT(A) and dismiss the appeal filed by the Revenue. 15. As the Cross Objection filed by the assessee is merely supportive of the CIT(A) order, therefore, the same is disposed of in terms of our aforesaid observations

M/S. Updater Services Ltd., Chennai vs. DCIT, Central Circle-2(3), Chennai

In the result, the grounds of appeal raised by both the assessee and the Revenue, as well as the grounds raised in the cross-objections filed by the assessee, are treated as allowed for statistical...

ITA 1339/CHNY/2025[2017-18]Status: DisposedITAT Chennai14 Nov 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1339 /Chny/2025 िनधा#रण वष# / Assessment Year: 2017-18 M/S. Updater Services Limited (Formerly Dcit, Known As Updater Services Private Vs. Central Circle -2(3), Limited), No.2/302-A, Uds Salai, Chennai. Off Old Mahabalipuram Road, Thoraipakkam, Chennai – 600 097. [Pan:Aaacu-6845-J] (अपीलाथ%/Appellant) (&'थ%/Respondent)

For Appellant: Shri. K. Prasanna, C.AFor Respondent: Ms. E. Pavuna Sundari, C.I.T
Section 115QSection 250Section 263Section 391Section 77A

/Date of Pronouncement : 14.11.2025 आदेश /O R D E R PER S. R. RAGHUNATHA, AM: These appeals filed by the assessee and revenue and cross objections filed by the assessee are directed against the order of the learned Commissioner of Income Tax (Appeals), Chennai, (in short “ld.CIT ... under Section 36(1)(iii) of the Act deleted) 14. Aggrieved by the above order of the Ld.CIT(A), the present cross appeals and cross objections are filed before us. :-8-: ITA Nos.:1339, 1616/Chny/2025 & C.O.No.66/Chny/2025 15. The Ld.AR, appearing on behalf of the assessee vehemently argued and filed

ACIT, New Delhi vs. M/S Sbk Trade and Infrastructure Private Limited, New Delhi

ITA 2173/DEL/2025[2015-16]Status: DisposedITAT Delhi14 Nov 2025AY 2015-16

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharmaacit, Cc – 04, Vs. M/S. Sbk Trade & Infrastructure Private Ltd., New Delhi. 211, New Delhi House, 27, Barakhamba Road, Connaught Place, New Delhi – 110 001. (Pan : Aarcs9589C) Co No.110 /Del/2025 (In Ita No.2173/Del/2025) (Assessment Year : 2015-16) M/S. Sbk Trade & Infrastructure Private Ltd., Vs. Acit, Cc – 04, 211, New Delhi House, New Delhi. 27, Barakhamba Road, Connaught Place, New Delhi – 110 001. (Pan : Aarcs9589C) (Appellant) (Respondent) Assessee By : Shri Mukesh Jain, Ca Shri Samyak Jain, Advocate Revenue By : Shri Ajay Kumar Arora, Sr. Dr Date Of Hearing : 29.10.2025 Date Of Order : 14.11.2025 O R D E R Per S.Rifaur Rahman: 1. The Revenue Has Filed Appeal Against The Order Of Ld. Commissioner Of Income Tax (Appeals), Delhi-23 [“Ld. Cit(A)”, For Short] Dated

For Appellant: Shri Mukesh Jain, CAFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 148Section 149(1)(b)Section 151Section 151(1)Section 151(2)Section 3

Income Tax (Appeals), Delhi-23 [“ld. CIT(A)”, for short] dated 2 CO No.110/Del/2025 07.01.2025 for AY 2015-16. The assessee has also filed cross objections in the aforesaid assessment year. 2. Since the issues are common and the appeals and cross objections are connected, hence the same are heard ... together and being disposed off by this common order. 3. First we proceed to hear the cross objections raised by the assessee. CO No.120/Del/2025 (AY 2015-16) 4. The assessee has taken the following ground of appeal in the cross objections :- “That having regard to the facts and circumstances