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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

Dr. Shruti Ramrao Shejole, Aashram Road vs. Harshadkumar Kantilal Savaliya, Iscon Temple Ahmedabad

ITA 663/AHD/2024[2020-21]Status: DisposedITAT Ahmedabad18 Sept 2025AY 2020-21

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) / Co By : It(Ss)A/Ita Assess- No(S) अपीलाथ' / !(थ' / No(S) /Co No. Ment Appellant बनाम/Vs. Respondent Year(S) 1. It(Ss)A No. 2019-20 Dcit Central Gsg Abode Llp 21/Ahd/2024 Circle-1(2) 1001, 10Th Floor Ahmedabad – 380 Safal Profitaire, 009 Corporate Road Navrangpura Ahmedabad – 380 006 Pan:Aatfg 0941 R (Assessee) (Revenue) 2. Co No. 2019-20 Gsg Abode Llp Dcit Central Circle- 32/Ahd/2024 1001, 10Th Floor 1(2) (In Itss)A Safal Profitaire, Ahmedabad – 380 009 No.21/Ahd/2024) Corporate Road Navrangpura Ahmedabad – 380 006 Pan:Aatfg 0941 R (Assessee) 3. Ita 2020-21 Dcit Central Csg Abode Llp 665/Ahd/2024 Circle-1(2) Ahmedabad-380 006 Ahmedabad- -380 009 4. It(Ss)A 2019-20 Dcit, Cen.Cir-1(2) Hitendrakumar 19/Ahd/2024 Ahmedabad- Bhailalbhai Patel -380 009 4A Bhailalbhai Bhavan 4A Ketan Society Nr.Sardar Patel Colony Navjivan Post Naranpura-380 014 Pan: Afupp 4221 K 5. It(Ss)A 2019-20 Dcit, Cen.Cir-1(2) Janki Dharmik Patel 20/Ahd/2024 Ahmedabad Ahmeeabad-380 009 Pan: Anjpp 8960 E

Section 153CSection 69B

separate orders of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as ‘CIT(A)’]. Cross Objection No.32/Ahd/2024 for AY 2019-20 has been filed by the assessee, GSG Abode LLP, Ahmedabad. Since common facts and issues involved in all the appeals are identical ... grounds of appeal taken by the Revenue in the case of GSG Abode LLP in IT(SS)A No.21/Ahd/2024 for AY 2019-20 and Cross Objection by the assessee in CO No.32/Ahd/2024 for AY 2019-20 are reproduced as under: IT(SS)A No.21/Ahd/2024 for AY 2019-20: “1) Whether

DCIT, Central Circle-1(2), Ahmedabad, Aaykar Bhawan Ashram Road Ahmedabad vs. Kantibhai Tapubhai Savalia, Scon Tample Ahmedabad

ITA 662/AHD/2024[2020-21]Status: DisposedITAT Ahmedabad18 Sept 2025AY 2020-21

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) / Co By : It(Ss)A/Ita Assess- No(S) अपीलाथ' / !(थ' / No(S) /Co No. Ment Appellant बनाम/Vs. Respondent Year(S) 1. It(Ss)A No. 2019-20 Dcit Central Gsg Abode Llp 21/Ahd/2024 Circle-1(2) 1001, 10Th Floor Ahmedabad – 380 Safal Profitaire, 009 Corporate Road Navrangpura Ahmedabad – 380 006 Pan:Aatfg 0941 R (Assessee) (Revenue) 2. Co No. 2019-20 Gsg Abode Llp Dcit Central Circle- 32/Ahd/2024 1001, 10Th Floor 1(2) (In Itss)A Safal Profitaire, Ahmedabad – 380 009 No.21/Ahd/2024) Corporate Road Navrangpura Ahmedabad – 380 006 Pan:Aatfg 0941 R (Assessee) 3. Ita 2020-21 Dcit Central Csg Abode Llp 665/Ahd/2024 Circle-1(2) Ahmedabad-380 006 Ahmedabad- -380 009 4. It(Ss)A 2019-20 Dcit, Cen.Cir-1(2) Hitendrakumar 19/Ahd/2024 Ahmedabad- Bhailalbhai Patel -380 009 4A Bhailalbhai Bhavan 4A Ketan Society Nr.Sardar Patel Colony Navjivan Post Naranpura-380 014 Pan: Afupp 4221 K 5. It(Ss)A 2019-20 Dcit, Cen.Cir-1(2) Janki Dharmik Patel 20/Ahd/2024 Ahmedabad Ahmeeabad-380 009 Pan: Anjpp 8960 E

Section 153CSection 69B

separate orders of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as ‘CIT(A)’]. Cross Objection No.32/Ahd/2024 for AY 2019-20 has been filed by the assessee, GSG Abode LLP, Ahmedabad. Since common facts and issues involved in all the appeals are identical ... grounds of appeal taken by the Revenue in the case of GSG Abode LLP in IT(SS)A No.21/Ahd/2024 for AY 2019-20 and Cross Objection by the assessee in CO No.32/Ahd/2024 for AY 2019-20 are reproduced as under: IT(SS)A No.21/Ahd/2024 for AY 2019-20: “1) Whether

Deputy Commissioner of Income Tax, Circle 2(1)(1), Vadodara vs. Truform Techno Products Private Limited, Nagpur

In the result, the appeal of the Revenue is partly allowed

ITA 1776/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad18 Sept 2025AY 2012-13

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2009-10

Section 143(2)Section 143(3)Section 147Section 148Section 151Section 68Section 78(2)

Appeal Centre (NFAC), Delhi (in short “the CIT(A)”) dated 14.08.2024 and 19.08.2024 for the Assessment Years (A.Y.) 2009-10 & 12-13 respectively. The Cross Objection No.42/Ahd/2025 is filed by the assessee in Appeal No.1775/Ahd/2024 for the A.Y. 2009-10. As the facts involved in these appeals and cross objection ... Truform Techno Products Pvt. Ltd. Page 3 of 22 3. The grounds taken by the Revenue and the assessee in this appeal and the cross objection are as under:- ITA No.1775/Ahd/2024 – A.Y. 2009-10 “(i) On the facts and circumstances of the case and in law, the Ld. CITA) erred

Deputy Commissioner of Income Tax, Circle 2(1)(1), Vadodara vs. Truform Techno Products Private Limited, Nagpur

In the result, the appeal of the Revenue is partly allowed

ITA 1775/AHD/2024[2009-10]Status: DisposedITAT Ahmedabad18 Sept 2025AY 2009-10

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2009-10

Section 143(2)Section 143(3)Section 147Section 148Section 151Section 68Section 78(2)

Appeal Centre (NFAC), Delhi (in short “the CIT(A)”) dated 14.08.2024 and 19.08.2024 for the Assessment Years (A.Y.) 2009-10 & 12-13 respectively. The Cross Objection No.42/Ahd/2025 is filed by the assessee in Appeal No.1775/Ahd/2024 for the A.Y. 2009-10. As the facts involved in these appeals and cross objection ... Truform Techno Products Pvt. Ltd. Page 3 of 22 3. The grounds taken by the Revenue and the assessee in this appeal and the cross objection are as under:- ITA No.1775/Ahd/2024 – A.Y. 2009-10 “(i) On the facts and circumstances of the case and in law, the Ld. CITA) erred

Asst. Commissioner of Income Tax-3(2)(1), Mumbai, Aayakar Bhavan vs. Solapur Yedeshi Tollway Limited, Mumbai

ITA 4242/MUM/2025[2017]Status: DisposedITAT Mumbai18 Sept 2025

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Ms. Padmavathy S, Hon’Bleacit 3(2)(1), Solapur Yedeshi Tollway Limited, Off No.11Th Floor, 1101, Mumbai Vs. Hiranandani Knowledge Park, Technology Street, Powai, Mumbai 400 076. Pan Aaucs1433Q (Appellant) (Respondent)

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Swapnil Choudhary – Sr AR
Section 143(2)Section 143(3)Section 147Section 37

r.w.s 144B of the Act. 4. In appeal, the CIT(A) has deleted the addition on merits. 5. The assessee has filed the cross objection challenging the refusal by the CIT(A) to examine the issue of reopening. 6. The Assessing Officer has found that during the relevant year ... assessee had succeeded. Be that as it may, we find that the Assessing Officer was not justified in re- opening the assessment and the cross-objection deserves to succeed. 14. Coming to the merits, Clause 6 of EPC Contract reads as under: “6. Mobilization/ Other Advances

ITO, Kolkata vs. Ajit Kumar Minda, Kolkata

ITA 2668/KOL/2024[2015-16]Status: DisposedITAT Kolkata17 Sept 2025AY 2015-16

Bench: Shri Manunatha G & Shri Sonjoy Sarmaι.Τ.Α. No.2668/Kol/2024

Section 10(38)Section 142(1)Section 143(3)Section 147Section 148Section 250Section 68Section 69C

Date of pronouncing the order : September 17, 2025 ORDER Per Sonjoy Sarma, Judicial Member: This is an appeal by the Revenue and Cross Objections by the assessee against the order of the National Faceless Appeal Centre [hereinafter referred to as the ‘CIT(A)'] dated 01.05.2024 passed

M/S. Patanjali Foods Ltd (Formerly Known As Ruchi Soya Industries Ltd), Mumbai vs. Dy Comm of Income Tax- Central Circle-7(2), Mumbai

In the result the appeal filed by the revenue stands

ITA 321/MUM/2023[2011-12]Status: DisposedITAT Mumbai17 Sept 2025AY 2011-12

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 132Section 143(3)Section 153ASection 250Section 37(1)

assessment for AY 2010-11 in the proceedings u/s 153A of the Act. Accordingly, the Additional Ground No. 7 raised in support of the cross objections is found to be maintainable and the preliminary objection of the Revenue is rejected. 5.6 Thus considering the above mentioned decision and also keeping ... while computing income under the normal provisions as well as book profit u/s 115JB of the Act. This additional ground no. 1 of the cross objections therefore stands partly allowed for statistical purpose. 5.10 Therefore, respectfully following the decision of the Coordinate Bench of Hon'ble ITAT in assessee

Patanjali Foods Ltd (Formerly Known As Ruchi Soya Industries Ltd), Mumbai vs. Dy Comm of Income Tax-Central Circle-7(2), Mumbai

In the result the appeal filed by the revenue stands

ITA 319/MUM/2023[2007-08]Status: DisposedITAT Mumbai17 Sept 2025AY 2007-08

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 132Section 143(3)Section 153ASection 250Section 37(1)

assessment for AY 2010-11 in the proceedings u/s 153A of the Act. Accordingly, the Additional Ground No. 7 raised in support of the cross objections is found to be maintainable and the preliminary objection of the Revenue is rejected. 5.6 Thus considering the above mentioned decision and also keeping ... while computing income under the normal provisions as well as book profit u/s 115JB of the Act. This additional ground no. 1 of the cross objections therefore stands partly allowed for statistical purpose. 5.10 Therefore, respectfully following the decision of the Coordinate Bench of Hon'ble ITAT in assessee

DCIT, CC-7(2), Mumbai vs. M/S. Patanjali Foods Ltd., ( Formerly Known As Ruchi Soya Industries Ltd, Mumbai

In the result the appeal filed by the revenue stands dismissed

ITA 1174/MUM/2023[2011-12]Status: DisposedITAT Mumbai17 Sept 2025AY 2011-12

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 132Section 143(3)Section 153ASection 250Section 37(1)

assessment for AY 2010-11 in the proceedings u/s 153A of the Act. Accordingly, the Additional Ground No. 7 raised in support of the cross objections is found to be maintainable and the preliminary objection of the Revenue is rejected. 5.6 Thus considering the above mentioned decision and also keeping ... while computing income under the normal provisions as well as book profit u/s 115JB of the Act. This additional ground no. 1 of the cross objections therefore stands partly allowed for statistical purpose. 5.10 Therefore, respectfully following the decision of the Coordinate Bench of Hon’ble ITAT in assessee

DCIT, CC-7(2), Mumbai vs. M/S. Patanjali Foods Ltd., ( Formerly Known As Ruchi Soya Industries Ltd, Mumbai

In the result the appeal filed by the revenue stands dismissed

ITA 1173/MUM/2023[2011-12]Status: DisposedITAT Mumbai17 Sept 2025AY 2011-12

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 132Section 143(3)Section 153ASection 250Section 37(1)

assessment for AY 2010-11 in the proceedings u/s 153A of the Act. Accordingly, the Additional Ground No. 7 raised in support of the cross objections is found to be maintainable and the preliminary objection of the Revenue is rejected. 5.6 Thus considering the above mentioned decision and also keeping ... while computing income under the normal provisions as well as book profit u/s 115JB of the Act. This additional ground no. 1 of the cross objections therefore stands partly allowed for statistical purpose. 5.10 Therefore, respectfully following the decision of the Coordinate Bench of Hon’ble ITAT in assessee

Dy. Commissioner of Income Tax, Jhandewalan vs. Kalamkari Designs Private Limited, New Delhi

ITA 342/DEL/2024[2015-16]Status: DisposedITAT Delhi17 Sept 2025AY 2015-16

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 1

issues being common, interlinked and related to the different assessee in captioned appeals filed by Revenue and the assessee and Cross-objections filed by assessee for various Assessment years, therefore, all these appeals filed by the Revenue and the assessee and cross-objection filed by the assessee have been heard ... account of bogus expenses without contravening the findings of the Assessing Officers that all job work contractors 7. The assessee has also filed cross-objection wherein following grounds of appeal were taken:- 1. “On the facts and circumstances of the case, the order passed by the learned Commissioner of Income

Dy. CIT, CC-4, Delhi, Jhandewalan vs. Kalamkari Designs Private Limited, Delhi

ITA 341/DEL/2024[2014-15]Status: DisposedITAT Delhi17 Sept 2025AY 2014-15

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 1

issues being common, interlinked and related to the different assessee in captioned appeals filed by Revenue and the assessee and Cross-objections filed by assessee for various Assessment years, therefore, all these appeals filed by the Revenue and the assessee and cross-objection filed by the assessee have been heard ... appellant craves to add, amend any/all the grounds of appeal before or during the hearing of the appeal.” 7. The assessee has also filed cross-objection wherein following grounds of appeal were taken:- 1. “On the facts and circumstances of the case, the order passed by the learned Commissioner

Dy. CIT, CC-04, Delhi vs. Kalamkari Designs Private Limited, Delhi

ITA 340/DEL/2024[2013-14]Status: DisposedITAT Delhi17 Sept 2025AY 2013-14

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 1

issues being common, interlinked and related to the different assessee in captioned appeals filed by Revenue and the assessee and Cross-objections filed by assessee for various Assessment years, therefore, all these appeals filed by the Revenue and the assessee and cross-objection filed by the assessee have been heard ... appellant craves to add, amend any/all the grounds of appeal before or during the hearing of the appeal.” 7. The assessee has also filed cross-objection wherein following grounds of appeal were taken:- 1. “On the facts and circumstances of the case, the order passed by the learned Commissioner

Reliance Ritu Kumar Pvt. Ltd., (Earlierknown As Ritika Pvt.Ltd., )R, New Delhi vs. ACIT, Central Circle-4, Delhi

ITA 231/DEL/2024[2018-19]Status: DisposedITAT Delhi17 Sept 2025AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 1

issues being common, interlinked and related to the different assessee in captioned appeals filed by Revenue and the assessee and Cross-objections filed by assessee for various Assessment years, therefore, all these appeals filed by the Revenue and the assessee and cross-objection filed by the assessee have been heard ... appellant craves to add, amend any/all the grounds of appeal before or during the hearing of the appeal.” 7. The assessee has also filed cross-objection wherein following grounds of appeal were taken:- 1. “On the facts and circumstances of the case, the order passed by the learned Commissioner

Dy. CIT, CC-04, Delhi, Ara Centre, Jhandewalan Extension New Delhi vs. Reliance Ritu Kumar Pvt Ltd (Earlier Known As Ritika Pvt. Ltd.), New Delhi

ITA 128/DEL/2024[2018-19]Status: DisposedITAT Delhi17 Sept 2025AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 1

issues being common, interlinked and related to the different assessee in captioned appeals filed by Revenue and the assessee and Cross-objections filed by assessee for various Assessment years, therefore, all these appeals filed by the Revenue and the assessee and cross-objection filed by the assessee have been heard ... appellant craves to add, amend any/all the grounds of appeal before or during the hearing of the appeal.” 7. The assessee has also filed cross-objection wherein following grounds of appeal were taken:- 1. “On the facts and circumstances of the case, the order passed by the learned Commissioner

Reliance Ritu Kumar Pvt. Ltd. (Earlier Known As Ritika Private Limited), Tilak Marg vs. ACIT, Central Circle-4, Delhi, Central Circle

ITA 3053/DEL/2023[2017-18]Status: DisposedITAT Delhi17 Sept 2025AY 2017-18

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 1

issues being common, interlinked and related to the different assessee in captioned appeals filed by Revenue and the assessee and Cross-objections filed by assessee for various Assessment years, therefore, all these appeals filed by the Revenue and the assessee and cross-objection filed by the assessee have been heard ... appellant craves to add, amend any/all the grounds of appeal before or during the hearing of the appeal.” 7. The assessee has also filed cross-objection wherein following grounds of appeal were taken:- 1. “On the facts and circumstances of the case, the order passed by the learned Commissioner

DCIT, New Delhi vs. Reliance Ritu Kumar Pvt. Ltd.(Earlier Known As Ritika Pvt. Ltd.), New Delhi

ITA 2944/DEL/2023[2017-18]Status: DisposedITAT Delhi17 Sept 2025AY 2017-18

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 1

issues being common, interlinked and related to the different assessee in captioned appeals filed by Revenue and the assessee and Cross-objections filed by assessee for various Assessment years, therefore, all these appeals filed by the Revenue and the assessee and cross-objection filed by the assessee have been heard ... appellant craves to add, amend any/all the grounds of appeal before or during the hearing of the appeal.” 7. The assessee has also filed cross-objection wherein following grounds of appeal were taken:- 1. “On the facts and circumstances of the case, the order passed by the learned Commissioner

Deputy Commissioner of Income Tax, Central Circle-04, New Delhi vs. Reliance Ritu Kumar Pvt. Ltd.(Earlier Known As Ritika Pvt. Ltd.), New Delhi

ITA 2748/DEL/2023[2015-16]Status: DisposedITAT Delhi17 Sept 2025AY 2015-16

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 1

issues being common, interlinked and related to the different assessee in captioned appeals filed by Revenue and the assessee and Cross-objections filed by assessee for various Assessment years, therefore, all these appeals filed by the Revenue and the assessee and cross-objection filed by the assessee have been heard ... appellant craves to add, amend any/all the grounds of appeal before or during the hearing of the appeal.” 7. The assessee has also filed cross-objection wherein following grounds of appeal were taken:- 1. “On the facts and circumstances of the case, the order passed by the learned Commissioner

Deputy Commissioner of Income Tax, New Delhi vs. Reliance Ritu Kumar Pvt. Ltd.(Earlier Known As Ritika Pvt. Ltd.), New Delhi

ITA 2696/DEL/2023[2014-15]Status: DisposedITAT Delhi17 Sept 2025AY 2014-15

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 1

issues being common, interlinked and related to the different assessee in captioned appeals filed by Revenue and the assessee and Cross-objections filed by assessee for various Assessment years, therefore, all these appeals filed by the Revenue and the assessee and cross-objection filed by the assessee have been heard ... appellant craves to add, amend any/all the grounds of appeal before or during the hearing of the appeal.” 7. The assessee has also filed cross-objection wherein following grounds of appeal were taken:- 1. “On the facts and circumstances of the case, the order passed by the learned Commissioner

Dy. Commissioner of Income Tax Central Circle-04, New Delhi vs. Reliance Ritu Kumar Pvt. Ltd.(Earlier Known As Ritika Pvt. Ltd.), New Delhi

ITA 2279/DEL/2023[2016-17]Status: DisposedITAT Delhi17 Sept 2025AY 2016-17

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 1

issues being common, interlinked and related to the different assessee in captioned appeals filed by Revenue and the assessee and Cross-objections filed by assessee for various Assessment years, therefore, all these appeals filed by the Revenue and the assessee and cross-objection filed by the assessee have been heard ... appellant craves to add, amend any/all the grounds of appeal before or during the hearing of the appeal.” 7. The assessee has also filed cross-objection wherein following grounds of appeal were taken:- 1. “On the facts and circumstances of the case, the order passed by the learned Commissioner