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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

Sahara India Limited, Lucknow vs. The ACIT., New Delhi

ITA 1243/DEL/2009[2003-04]Status: DisposedITAT Delhi10 Feb 2026AY 2003-04

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Year: 1996-97 With Assessment Year: 2003-04 Sahara India Limited, Vs. Acit, Central Circle-I, I - Kapoorthala Complex, Lucknow Aliganj, Lucknow Pan: Aadcs4402J (Appellant) (Respondent) With Ita No.45/Lkw/2006 Along With C.O. No.36/Lkw/2006 Assessment Year: 1997-98 With Ita No.46/Lkw/2006 Along With C.O. No.37/Lkw/2006 Assessment Year: 1998-99 With Ita No.78/Lkw/2006 Along With C.O. No.39/Lkw/2006 Assessment Year: 2000-01 With Ita No.127/Lkw/2006 Along With C.O. No.40/Lkw/2006 Assessment Year: 2001-02 Acit, Central Circle-I, Vs. Sahara India Limited, Lucknow I-Kapoorthala Complex, Aliganj, Lucknow Pan: Aadcs4402J (Appellant) (Respondent/Cross-Objector) Assessee By Sh. Percy Pardiwala, Sr. Advocate Sh. Devashish A Mehrotra, Ca Sh. Sarvesh Srivastava, Advocate Department By Ms. Monika Singh, Cit(Dr)

Section 143(3)Section 2(22)(e)

crores in the assessee’s hands for the precise reason to allow its main appeal ITA No.898/Lkw/2005 in very terms. C.O. No.36/Lkw/2006 (Assessee’s cross objection) AY: 1997-98 5. Learned CIT(DR) vehemently argues during the course of hearing that the CIT(A) herein has erred ... 40/Lkw/2006 in preceding terms. This Revenue’s appeal ITA No. 45/Lkw/2006 stands declined therefore. 8. Learned senior counsel clarifies that the assessee’s cross objection herein C.O. No. 36/Lkw/2006 is only supportive of the CIT(A)’s impugned lower appellate discussion. Dismissed as rendered infructuous. C.O. No. 37/Lkw/2006 (Assessee

ACIT, Lucknow vs. Sahara India Ltd., Lucknow

ITA 78/LKW/2006[2000-01]Status: DisposedITAT Delhi10 Feb 2026AY 2000-01

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Year: 1996-97 With Assessment Year: 2003-04 Sahara India Limited, Vs. Acit, Central Circle-I, I - Kapoorthala Complex, Lucknow Aliganj, Lucknow Pan: Aadcs4402J (Appellant) (Respondent) With Ita No.45/Lkw/2006 Along With C.O. No.36/Lkw/2006 Assessment Year: 1997-98 With Ita No.46/Lkw/2006 Along With C.O. No.37/Lkw/2006 Assessment Year: 1998-99 With Ita No.78/Lkw/2006 Along With C.O. No.39/Lkw/2006 Assessment Year: 2000-01 With Ita No.127/Lkw/2006 Along With C.O. No.40/Lkw/2006 Assessment Year: 2001-02 Acit, Central Circle-I, Vs. Sahara India Limited, Lucknow I-Kapoorthala Complex, Aliganj, Lucknow Pan: Aadcs4402J (Appellant) (Respondent/Cross-Objector) Assessee By Sh. Percy Pardiwala, Sr. Advocate Sh. Devashish A Mehrotra, Ca Sh. Sarvesh Srivastava, Advocate Department By Ms. Monika Singh, Cit(Dr)

Section 143(3)Section 2(22)(e)

crores in the assessee’s hands for the precise reason to allow its main appeal ITA No.898/Lkw/2005 in very terms. C.O. No.36/Lkw/2006 (Assessee’s cross objection) AY: 1997-98 5. Learned CIT(DR) vehemently argues during the course of hearing that the CIT(A) herein has erred ... 40/Lkw/2006 in preceding terms. This Revenue’s appeal ITA No. 45/Lkw/2006 stands declined therefore. 8. Learned senior counsel clarifies that the assessee’s cross objection herein C.O. No. 36/Lkw/2006 is only supportive of the CIT(A)’s impugned lower appellate discussion. Dismissed as rendered infructuous. C.O. No. 37/Lkw/2006 (Assessee

ACIT, Lucknow vs. Sahara India Ltd., Lucknow

ITA 46/LKW/2006[1998-99]Status: DisposedITAT Delhi10 Feb 2026AY 1998-99

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Year: 1996-97 With Assessment Year: 2003-04 Sahara India Limited, Vs. Acit, Central Circle-I, I - Kapoorthala Complex, Lucknow Aliganj, Lucknow Pan: Aadcs4402J (Appellant) (Respondent) With Ita No.45/Lkw/2006 Along With C.O. No.36/Lkw/2006 Assessment Year: 1997-98 With Ita No.46/Lkw/2006 Along With C.O. No.37/Lkw/2006 Assessment Year: 1998-99 With Ita No.78/Lkw/2006 Along With C.O. No.39/Lkw/2006 Assessment Year: 2000-01 With Ita No.127/Lkw/2006 Along With C.O. No.40/Lkw/2006 Assessment Year: 2001-02 Acit, Central Circle-I, Vs. Sahara India Limited, Lucknow I-Kapoorthala Complex, Aliganj, Lucknow Pan: Aadcs4402J (Appellant) (Respondent/Cross-Objector) Assessee By Sh. Percy Pardiwala, Sr. Advocate Sh. Devashish A Mehrotra, Ca Sh. Sarvesh Srivastava, Advocate Department By Ms. Monika Singh, Cit(Dr)

Section 143(3)Section 2(22)(e)

crores in the assessee’s hands for the precise reason to allow its main appeal ITA No.898/Lkw/2005 in very terms. C.O. No.36/Lkw/2006 (Assessee’s cross objection) AY: 1997-98 5. Learned CIT(DR) vehemently argues during the course of hearing that the CIT(A) herein has erred ... 40/Lkw/2006 in preceding terms. This Revenue’s appeal ITA No. 45/Lkw/2006 stands declined therefore. 8. Learned senior counsel clarifies that the assessee’s cross objection herein C.O. No. 36/Lkw/2006 is only supportive of the CIT(A)’s impugned lower appellate discussion. Dismissed as rendered infructuous. C.O. No. 37/Lkw/2006 (Assessee

ACIT, Lucknow vs. Sahara India Ltd., Lucknow

ITA 45/LKW/2006[1997-98]Status: DisposedITAT Delhi10 Feb 2026AY 1997-98

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Year: 1996-97 With Assessment Year: 2003-04 Sahara India Limited, Vs. Acit, Central Circle-I, I - Kapoorthala Complex, Lucknow Aliganj, Lucknow Pan: Aadcs4402J (Appellant) (Respondent) With Ita No.45/Lkw/2006 Along With C.O. No.36/Lkw/2006 Assessment Year: 1997-98 With Ita No.46/Lkw/2006 Along With C.O. No.37/Lkw/2006 Assessment Year: 1998-99 With Ita No.78/Lkw/2006 Along With C.O. No.39/Lkw/2006 Assessment Year: 2000-01 With Ita No.127/Lkw/2006 Along With C.O. No.40/Lkw/2006 Assessment Year: 2001-02 Acit, Central Circle-I, Vs. Sahara India Limited, Lucknow I-Kapoorthala Complex, Aliganj, Lucknow Pan: Aadcs4402J (Appellant) (Respondent/Cross-Objector) Assessee By Sh. Percy Pardiwala, Sr. Advocate Sh. Devashish A Mehrotra, Ca Sh. Sarvesh Srivastava, Advocate Department By Ms. Monika Singh, Cit(Dr)

Section 143(3)Section 2(22)(e)

crores in the assessee’s hands for the precise reason to allow its main appeal ITA No.898/Lkw/2005 in very terms. C.O. No.36/Lkw/2006 (Assessee’s cross objection) AY: 1997-98 5. Learned CIT(DR) vehemently argues during the course of hearing that the CIT(A) herein has erred ... 40/Lkw/2006 in preceding terms. This Revenue’s appeal ITA No. 45/Lkw/2006 stands declined therefore. 8. Learned senior counsel clarifies that the assessee’s cross objection herein C.O. No. 36/Lkw/2006 is only supportive of the CIT(A)’s impugned lower appellate discussion. Dismissed as rendered infructuous. C.O. No. 37/Lkw/2006 (Assessee

ACIT, Lucknow vs. Sahara India Ltd., Lucknow

ITA 127/LKW/2006[2001-02]Status: DisposedITAT Delhi10 Feb 2026AY 2001-02

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Year: 1996-97 With Assessment Year: 2003-04 Sahara India Limited, Vs. Acit, Central Circle-I, I - Kapoorthala Complex, Lucknow Aliganj, Lucknow Pan: Aadcs4402J (Appellant) (Respondent) With Ita No.45/Lkw/2006 Along With C.O. No.36/Lkw/2006 Assessment Year: 1997-98 With Ita No.46/Lkw/2006 Along With C.O. No.37/Lkw/2006 Assessment Year: 1998-99 With Ita No.78/Lkw/2006 Along With C.O. No.39/Lkw/2006 Assessment Year: 2000-01 With Ita No.127/Lkw/2006 Along With C.O. No.40/Lkw/2006 Assessment Year: 2001-02 Acit, Central Circle-I, Vs. Sahara India Limited, Lucknow I-Kapoorthala Complex, Aliganj, Lucknow Pan: Aadcs4402J (Appellant) (Respondent/Cross-Objector) Assessee By Sh. Percy Pardiwala, Sr. Advocate Sh. Devashish A Mehrotra, Ca Sh. Sarvesh Srivastava, Advocate Department By Ms. Monika Singh, Cit(Dr)

Section 143(3)Section 2(22)(e)

crores in the assessee’s hands for the precise reason to allow its main appeal ITA No.898/Lkw/2005 in very terms. C.O. No.36/Lkw/2006 (Assessee’s cross objection) AY: 1997-98 5. Learned CIT(DR) vehemently argues during the course of hearing that the CIT(A) herein has erred ... 40/Lkw/2006 in preceding terms. This Revenue’s appeal ITA No. 45/Lkw/2006 stands declined therefore. 8. Learned senior counsel clarifies that the assessee’s cross objection herein C.O. No. 36/Lkw/2006 is only supportive of the CIT(A)’s impugned lower appellate discussion. Dismissed as rendered infructuous. C.O. No. 37/Lkw/2006 (Assessee

Sahara India Ltd., Lucknow vs. ACIT, Lucknow

ITA 898/LKW/2005[1996-97]Status: DisposedITAT Delhi10 Feb 2026AY 1996-97

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Year: 1996-97 With Assessment Year: 2003-04 Sahara India Limited, Vs. Acit, Central Circle-I, I - Kapoorthala Complex, Lucknow Aliganj, Lucknow Pan: Aadcs4402J (Appellant) (Respondent) With Ita No.45/Lkw/2006 Along With C.O. No.36/Lkw/2006 Assessment Year: 1997-98 With Ita No.46/Lkw/2006 Along With C.O. No.37/Lkw/2006 Assessment Year: 1998-99 With Ita No.78/Lkw/2006 Along With C.O. No.39/Lkw/2006 Assessment Year: 2000-01 With Ita No.127/Lkw/2006 Along With C.O. No.40/Lkw/2006 Assessment Year: 2001-02 Acit, Central Circle-I, Vs. Sahara India Limited, Lucknow I-Kapoorthala Complex, Aliganj, Lucknow Pan: Aadcs4402J (Appellant) (Respondent/Cross-Objector) Assessee By Sh. Percy Pardiwala, Sr. Advocate Sh. Devashish A Mehrotra, Ca Sh. Sarvesh Srivastava, Advocate Department By Ms. Monika Singh, Cit(Dr)

Section 143(3)Section 2(22)(e)

crores in the assessee’s hands for the precise reason to allow its main appeal ITA No.898/Lkw/2005 in very terms. C.O. No.36/Lkw/2006 (Assessee’s cross objection) AY: 1997-98 5. Learned CIT(DR) vehemently argues during the course of hearing that the CIT(A) herein has erred ... 40/Lkw/2006 in preceding terms. This Revenue’s appeal ITA No. 45/Lkw/2006 stands declined therefore. 8. Learned senior counsel clarifies that the assessee’s cross objection herein C.O. No. 36/Lkw/2006 is only supportive of the CIT(A)’s impugned lower appellate discussion. Dismissed as rendered infructuous. C.O. No. 37/Lkw/2006 (Assessee

Dilip Khandelwal ACIT Central Circle 2(1) Ahmedabad, Ahmedabad vs. Satyanarayan Jagannath Kabra, Ahmedabad

In the result, the appeal of the Revenue as well as the Cross Objections filed by the assessee stand dismissed

ITA 940/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad09 Feb 2026AY 2015-16

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.940/Ahd/2025 िनधा"रण वष" /Asst.Year 2015-16 The Acit Satyanarayan Jagannath Kabra बनाम/ Central Circle-2(1) 10, Amam Villa Bungalows V/S. Ahmedabad – 380 009 Hebatpura, Thaltej Ahmedabad – 380 014 Pan: Adgpk 2858 M अपीलाथ$/ (Appellant) %& यथ$/ (Respondent) .. & Cross Objection No.47/Ahd/2025 - िनधा"रण वष" /Ay 2015-16 (In Ita No.940/Ahd/2025 – Ay 2015-16) V/S. Satyanarayan Jagannath Kabra The Acit 10, Amam Villa Bungalows Central Circle-2(1) Hebatpura, Thaltej Ahmedabad – 380 009 Ahmedabad – 380 014 Pan: Adgpk 2858 M (Cross Objector) .. (Respondent)

For Appellant: Shri Sakar Sharma, ARFor Respondent: Shri Rignesh Das, CIT-DR
Section 133ASection 143(3)

Amam Villa Bungalows v/s. Ahmedabad – 380 009 Hebatpura, Thaltej Ahmedabad – 380 014 PAN: ADGPK 2858 M अपीलाथ$/ (Appellant) %& यथ$/ (Respondent) .. AND Cross Objection No.47/Ahd/2025 - िनधा"रण वष" /AY 2015-16 (in ITA No.940/Ahd/2025 – AY 2015-16) v/s. Satyanarayan Jagannath Kabra The ACIT 10, Amam Villa Bungalows Central Circle ... Hearing : 12/11/2025 घोषणा की तारीख /Date of Pronouncement: 09/02/2026 Per Sanjay Garg, Judicial member: The captioned is an appeal by the Revenue and corresponding cross objections by the assessee preferred against the order dated 18/02/2025 passed by the Learned Commissioner of Income Tax (Appeals)-12, Ahmedabad (hereinafter referred