“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

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

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

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

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

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

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

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

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

Income Tax Officer, Ward 7.2.1, Ahmedabad vs. Raghavbhai Gordhanbhai Narola, Ahmedabad

Appeals of the Revenue are hereby dismissed, whereas, all the Cross Objections filed by the assessee are hereby allowed

ITA 1266/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad09 Feb 2026AY 2013-14

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Shri Biren Shah, ARFor Respondent: Shri Hargovind Sinh, Sr.DR

Section 143(1)(a)Section 148Section 250

Pronouncement: 09/02/2026 आदेश/O R D E R Per Sanjay Garg, Judicial Member: The captioned appeals have been preferred by the Revenue and corresponding cross objections by the assessee are against separate orders of ITA Nos.1266 to 1268/Ahd/2025 (By Revenue) & CO Nos.55 to 57/Ahd/2025 (By Assessee) ITO vs. Raghavbhai Gordhanbhai ... ground before the final hearing of the appeal.” CO No.55/Ahd/2025 - AY 2013-14 (in ITA No.1266/Ahd/2025 – AY 2013-14) 3. The assessee, in its Cross Objection, has taken following grounds (Without prejudice to each other): ITA Nos.1266 to 1268/Ahd/2025 (By Revenue) & CO Nos.55 to 57/Ahd/2025 (By Assessee) ITO vs. Raghavbhai

Income Tax Officer, Chennai vs. Railway Employees Cooperative Credit Society, Chennai

In the result, the both the appeals filed by the Revenue are dismissed

ITA 2096/CHNY/2025[2018]Status: DisposedITAT Chennai09 Feb 2026

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Ms. R. Anitha, Addl. CITFor Respondent: Shri. Vignesh Kumarasamy, Advocate

Section 143(3)Section 80P(2)Section 80P(2)(a)

case of Jafari Momin Vikas Co-op Credit Society Ltd. v. ITO in I.T.A. No. 1491/Ahd/2012 for assessment year 2009-10, deciding the Cross Objection filed along with appeal [C.O. No. 138/Ahd/2012] in favour of the assessee and by following the decision of the Kolkata Benches of the Tribunal, wherein

Income Tax Officer, Chennai vs. Railway Employees Cooperative Credit Society Limited, Chennai

In the result, the both the appeals filed by the Revenue are dismissed

ITA 2095/CHNY/2025[2017-18]Status: DisposedITAT Chennai09 Feb 2026AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Ms. R. Anitha, Addl. CITFor Respondent: Shri. Vignesh Kumarasamy, Advocate

Section 143(3)Section 80P(2)Section 80P(2)(a)

DCIT (TDS)-2 3, Mumbai vs. Novartis India Limited, Mumbai

In the result, both the appeal of the Revenue and cross-

ITA 5681/MUM/2025[2016-17]Status: DisposedITAT Mumbai09 Feb 2026AY 2016-17

Bench: Shri Om Prakash Kant () And

Section 194HSection 201

Novartis India Ltd. 2 ITA No. 5681 & CO No. 302/MUM/2025 ORDER PER OM PRAKASH KANT, AM This appeal filed by the Revenue and the cross-objection filed by the assessee arise out of the order dated 16.07.2025 passed by the Learned Additional/Joint Commissioner of Income-tax (Appeals)—7, Kolkata [hereinafter ... section 194H in respect of trade discounts to stockists, and incorrect appreciation of the timing of tax deduction on ESOP benefits. 2.1 The cross objection raised by the assessee are reproduced as under: On the facts and in the circumstances of the case, the learned CIT(A) has erred

DCIT, New Delhi vs. Sh. Kunjan Arora, New Delhi

Accordingly, notice u/s 153C is liable to be quashed and the resultant order framed u/s 153C is also liable to be quashed. We order accordingly. The Cross Objection of the assessee is allowed

ITA 2772/DEL/2014[2009-10]Status: DisposedITAT Delhi09 Feb 2026AY 2009-10

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandradcit, Vs. Kunjan Arora, Central Circle-03, 2A/53, Geeta Colony, New Delhi Delhi (Appellant) (Respondent) Pan: Adkpa3182A Co 77/Del/2024 (In Ita No. 2772/Del/2014) (Assessment Year: 2009-10) Kunjan Arora, Vs. Dcit, 2A/53, Geeta Central Circle-03, Colony, New Delhi Delhi (Appellant) (Respondent) Pan: Adkpa3182A Assessee By : Shri Salil Kapoor, Adv Shri Rajan Malik, Adv Shri Utkarsa Gupta, Adv Revenue By: Ms. Monika Singh, Cit Dr Date Of Hearing 09/02/2026 Date Of Pronouncement 09/02/2026

For Appellant: Shri Salil Kapoor, AdvFor Respondent: Ms. Monika Singh, CIT DR

Section 153C

Aggrieved revenue is before us against the deletion of the addition made while the assessee is before us in Cross Objection on account of rejection of its ground with regard to assumption of jurisdiction u/s 153C of the Act. We take up the issue of assumption of jurisdiction u/s 153C ... 153C is liable to be quashed and the resultant order framed u/s 153C is also liable to be quashed. We order accordingly. The Cross Objection of the assessee is allowed. Since, the appeal has been decided on legal ground, the ground 10. of merit of the revenue become academic

Income Tax Officer, Ward-1, Gudiwada vs. Chagantipadu Primary Agricultural Co-Operative Credit Society Limited Noh957, Chagantipadu Village

In the result, the appeal by the Revenue and the cross objection by the

ITA 641/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam06 Feb 2026AY 2018-19

Bench: Shri Sandeep Singh Karhail, Hon’Ble

Section 147Section 148Section 250Section 69A

ulsun wt aNG/Date of Pronouncement > | 06.02.2026 Set /ORDER PER SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER: 1. The present appeal by the Revenue and cross objection by the assessee have been filed against the impugned order dated 26.08.2025 passed under section 250 of the Income Tax Act, 1961 (in short ... other grounds that may be urged at the time of hearing.” 3. While the assessee has raised the following grounds of appeal in its cross objection, on merits: - “1. The Id. CIT(A) ought to have held that the Assessing Officer wrongly added cash deposits u/s 69A, and further ought

DCIT, Vikash Bhawan Delhi vs. Rajan Kumar, Laxmi Nagar, Delhi

In the result, the appeal of the Revenue appeal is dismissed and the cross objection filed by the assessee is allowed in the aforesaid manner

ITA 130/DEL/2025[2012-13]Status: DisposedITAT Delhi06 Feb 2026AY 2012-13

Bench: Shri Sudhir Kumar & Smt. Renu Jauhridcit Vs Rajan Kumar Room No. 218-D Block, 31,Vijay Block Laxmi Vikash Bhawan, Nagar Delhi-110092 Delhi- 110 002 Pan: Caapk8381E

Section 132Section 142(1)Section 143(1)Section 147Section 148Section 69A

Rajan Kumar ROOM NO. 218-D BLOCK, 31,Vijay Block Laxmi VIKASH BHAWAN, Nagar Delhi-110092 DELHI- 110 002 PAN: CAAPK8381E (APPELLANT) (RESPONDENT) & Cross Objection No.124/Del/2025 (A.Y.2012-13) Rajan Kumar Vs DCIT 31,Vijay Block Laxmi Nagar ROOM NO. 218-D Delhi-110092 BLOCK, VIKASH PAN: CAAPK8381E BHAWAN, DELHI ... National Faceless Appeal Centre (NFAC) Delhi (in short “the Ld. NFAC)) relevant to assessment year 2012-13. The assessee also filed the cross objection for the Assessment Year 2012-13. 2. The Revenue has raised the following grounds in appeal: 1. Whether on the facts and in circumstances

ACIT, New Delhi vs. Sparsh Property Private Limited, Delhi

In the result, the Revenue’s appeal as well as Assessee’s cross objection stand dismissed

ITA 5849/DEL/2024[2016-17]Status: DisposedITAT Delhi06 Feb 2026AY 2016-17

Bench: Shri Mahavir Singh & Shri Krinwant Sahayacit, Vs. M/S Sparsh Property Room No. 261-A, 2Nd Floor, Private Limited, E-2, Jhandewalan Extn., 43, Community Center, New Delhi – 110 055 New Friends Colony, S.O. Zakir Nagar, South East Delhi, New Delhi – 110 025 (Pan: Aabcs8660C) (Appellant) (Respondent) C.O. No. 56/Del/2025 (Ita No. 5849/Del/2024) (Ay 2016-17)

For Appellant: Sh. Biren Shah, CA & Sh. Rohit Aggarwal, CAFor Respondent: Sh. Mahesh Kumar, CIT(DR)

Section 132Section 143(1)Section 148Section 68

Rohit Aggarwal, CA Date of Hearing 12.11.2025 Date of Pronouncement 06.2.2026 ORDER PER MAHAVIR SINGH, VP: The appeal filed by the Revenue and Cross Objection by the Assessee are directed against the order passed by the Ld. Commissioner of Income Tax (Appeals-23), New Delhi dated 1.9.2024 for A.Y. 2016-17.Since ... appeal and Cross Objection both are inter- connected, hence, the same were heard together and disposed of by this common order for the sake of convenience. 2. First we deal with Revenue’s appeal No. 5849/Del/2024, wherein, following effective grounds have been raised:- 1. The Ld. CIT(A) has erred

ACIT, New Delhi vs. Nouvelle Securities Pvt Ltd, Delhi

In the result, the appeal of the Revenue in ITA No

ITA 4852/DEL/2024[2016-17]Status: DisposedITAT Delhi06 Feb 2026AY 2016-17

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Biren Shah, CAFor Respondent: Shri Manoj Tiwari, Sr. DR

Section 132Section 132(4)Section 153ASection 37Section 68Section 69C

21/DEL/2025 [A.Y. 2016-17] Nouvelle Securities ORDER PER NAVEEN CHANDRA, A.M:- The above captioned appeal by the Revenue and cross objection of the assessee are directed against the order of the ld. CIT(A)- 23, New Delhi dated 27.02.2024 for A.Y 2016-17 respectively. 2. Since the appeal and cross ... appreciate that there is no information of conduct of any audit/in” 4. The assessee has raised the following grounds of appeal in its cross objections: “1. On the facts and in the circumstances of the case and in law, the learned CIT(A) ought to have deleted the addition

Income Tax Officer, Aaykar Bhawan vs. Shiv Shankar Rice Mills, Gogripur Road

In the result, the appeal of the Revenue is dismissed

ITA 4630/DEL/2024[2013-14]Status: DisposedITAT Delhi06 Feb 2026AY 2013-14

Bench: Shri Mahavir Singh & Shri Krinwant Sahay[Assessment Year: 2013-14]

Section 143(3)Section 147Section 148Section 151

SHIV SHANKAR RICE MILLS, Sector-12, Bay No.25-28, GOGRIPUR ROAD KARNAL, Urban Estate, Karnal, KARNAL, Haryana-132001 Haryana-132001 PAN :AADFS3923K (Revenue ) (Assessee) Cross Objection No.199/Del/2025 [Assessment Year: 2013-14] M/s SHIV SHANKAR RICE Vs. Income Tax Officer, MILLS, Sector-12, Bay No.25-28, GOGRIPUR RAILWAY PHATAK Urban Estate, Karnal, KARNAL ... section 147 r.w.s. 144 of the Income Tax Act, 1961 (hereinafter ‘the Act’) pertaining to Assessment Year 2023-24. The assessee has also filed Cross Objection. 2. Grounds of appeal raised by the Revenue are as under:- “1. Whether on the facts and in the circumstances of the case

DCIT, Central Circle-6, Third Floor vs. Rama Shankar Khemka, Ganesh Bazar

In the result, the appeal filed by the revenue and CO filed by the assessee are dismissed

ITA 1005/DEL/2024[2020-21]Status: DisposedITAT Delhi06 Feb 2026AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmandcit Vs. Payal Khemka Central Circle- 6 67/85-2 Jhun Bhawan, Natimalivaranashi Delhi Uttar Pradesh 221001 (Pan: Adtpj2728A) Dcit Vs. Pmk Impex Pvt. Ltd. Central Circle- 6 1 Tolstoy Marg, Connaught Place, Delhi New Delhi, Delhi 110001

For Appellant: Sh. Gautam Jain AdvFor Respondent: Sh. Jitender Singh, CIT DR

Section 132Section 132(4)

Date of Hearing : 18.11.2025 Date of Order : 06.02.2026 ORDER PER S. RIFAUR RAHMAN, ACCOUNTANT MEMBER : 1. These appeals are filed by the revenue and cross objections by the assessees against the order of ld. Commissioner of Income-tax (Appeals)-24, New Delhi (hereinafter referred to ‘ld. CIT (A)’) dated ... grounds raised by the revenue may kindly be rejected. 46 It is thus prayed that appeal filed by revenue may kindly be dismissed and cross objection filed by the assessee may kindly be allowed. 47 Similar findings of the learned Commissioner of Income Tax (Appeals) wherein deleted the addition

DCIT, Central Circle-6, Third Floor vs. Rajesh Rani Khemka, Ganesh Bazar

In the result, the appeal filed by the revenue and CO filed by the assessee are dismissed

ITA 1004/DEL/2024[2020-21]Status: DisposedITAT Delhi06 Feb 2026AY 2020-21

For Appellant: Sh. Gautam Jain AdvFor Respondent: Sh. Jitender Singh, CIT DR

Section 132Section 132(4)

DCIT, Central Circle-6, Income Tax Department vs. Pmk Impex Private Limited, Atma Ram House

ITA 1002/DEL/2024[2020-21]Status: DisposedITAT Delhi06 Feb 2026AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

For Appellant: Sh. Gautam Jain AdvFor Respondent: Sh. Jitender Singh, CIT DR

Section 132Section 132(4)

DCIT, Central Circle-6, Income Tax Department vs. Payal Khemka, K

In the result, the appeal filed by the revenue and CO filed by the assessee are dismissed

ITA 1000/DEL/2024[2020-21]Status: DisposedITAT Delhi06 Feb 2026AY 2020-21

For Appellant: Sh. Gautam Jain AdvFor Respondent: Sh. Jitender Singh, CIT DR

Section 132Section 132(4)

ACIT, Central Circle-2, Patna vs. Shri Nagendra Prasad, Patna

In the result, appeal of the revenue stands allowed

ITA 109/PAT/2020[2010-11]Status: DisposedITAT Patna05 Feb 2026AY 2010-11

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI LAXMI PRASAD SAHU (Accountant Member)

For Appellant: Shri N.K.Lal, FCAFor Respondent: Md. A.H.Chowdhary, CIT-DR

Section 143(3)Section 147

amounts were deposited the 8 statement recorded. With regard to point No.12, it must be mentioned here that the assessee has not filed any cross objection. No evidence of an earlier assessment under Section 143(3) of the Act is available. There is only allegation only of an assessment having ... been done u/s.143(3) of the Act. The cross objection, admittedly, is not there. Even Rule 27 of the ITAT Rules, 1963 have not have been invoked. This being so, we have no information that an earlier assessment has been done in the case of the assessee. It has also

DCIT, Central Circle-4(3), Kolkata vs. Raj Goenka, Kolkata

In the result, the appeal of the revenue is dismissed

ITA 1801/KOL/2025[2022-23]Status: DisposedITAT Kolkata05 Feb 2026AY 2022-23

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2022-23 Dcit, Cc-4(3), Kolkata……...……..……….………….……….……….……Appellant Vs. Raj Goenka…………………………………………..…….....……...…..…..Respondent 10Th Floor Magma House, 24, Park Street Park Street, Kol-16. [Pan: Adlpg8181C] Appearances By: Shri S B Chakraborthy, Addl. Cit, Appeared On Behalf Of The Appellant. Shri Miraj D. Shah, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 04, 2025 Date Of Pronouncing The Order : February 05, 2026 Order Per Pradip Kumar Choubey: This Appeal Filed By The Revenue Is Directed Against The Order Dated 12.04.2025 Of The Cit(Appeals)-27, Kolkata (Hereinafter Referred To As The “Cit(A)”) Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2022–23. 2. The Appeal Has Been Filed By The Revenue With A Delay Of 08 Days. The Revenue Has Filed A Petition For Condonation Of The Delay. After Considering The Reasons Cited In The Petition For Condonation Of Delay, We Find That The Reasons Are Valid & Consequently, The Delay In Filing The Appeal Is Hereby Condoned & We Proceed To Dispose Of The Appeal On Merits.

Section 127Section 132(1)Section 139Section 143(1)Section 143(2)Section 143(3)Section 250Section 68

hands of the present assessee. Obviously, the department being aggrieved preferred appeal before the Tribunal and at the same time, the present assessee filed cross objection regarding part of the income, to the extent of a sum of Rs. 5 Lacs, as being recorded in the hands of present assessee ... sufficient for the income to be assessed for a sum of Rs. 5Lacs in the hands of the assessee and while allowing the cross objection filed by the assessee dismissed the appeal preferred by the revenue under order impugned. We have heard the parties at length and of the view

Incometax Officer, Chennai vs. Chinnan Vaithyalingam, Chennai

In the result, the appeal of the Revenue and stay application of the

ITA 2348/CHNY/2025[2011]Status: DisposedITAT Chennai05 Feb 2026

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. T. Vasudevan, AdvocateFor Respondent: Shri. C. Sivakumar, Addl. C.-T

Section 144Section 148

atargs FT ANTG/Date of Hearing : 07.01.2026 arse il anrea/Date of Pronouncement : 05.02.2026 amaer/ORDER PER S. R. RAGHUNATHA, AM : The present appeal of the Revenue, Cross objections and Stay petition of the assessee are directed against the order dated 04.06.2025 of the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal ... allowed the appeal of the assessee. 7. Aggrieved of the above order of the Ld.CIT(A), Revenue is in appeal and the assessee filed cross objections before us. 8. The Ld.DR, appearing for the Revenue, submitted that the assessee has failed to file the return of income despite having taxable

ITO, Mumbai vs. Himanshu Sarda, Mumbai

ITA 5862/MUM/2025[2017-18]Status: DisposedITAT Mumbai05 Feb 2026AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokarito,Ward-42(1)(2), Mumbai Vs Himanshu Sarda Room No. 734, Kautilya 705/706, Shivalaya Residency Chs Bhawan, Bkc, Bandra (E) Ltd., Thakur Complex, 90 Feet Mumbai-400051 Road, Kandivali East, Mumbai- 400101 Pan: Flpps9753F Appellant Respondent C.O.410/Mum/2025 (Arising Out Of I.T.A. No.5862/Mum/2025 A.Y. :2017-18)

For Appellant: Shri Ajay R. Singh, Adv & Akshay Pawar, AdvFor Respondent: Shri Ritesh Misra (CIT DR)

Section 147Section 148Section 148ASection 151Section 250

pronouncement : 05/02/2026 2 ITA No.5862 & CO No.410/Mum/2025 Himanshu Sarda O R D E R Per Bench: The instant appeal of the revenue and cross-objection of the assessee filed against the order of the NFAC, Delhi [for brevity ‘the Ld. CIT(A)’], order passed under section 250 of the Income ... brevity the ‘Ld. AO’), order passed under section 147 r.w.s. 144B of the Act date of order 05.05.2023. 2. The registry inform that the cross-objection filed by the assessee with a delay for 37 days. The assessee explained the delay and filed the prayer for condonation of delay

Income Tax Officer, Ward-1(3)(4), Mumbai vs. Wizcraft Entertainment Agency Private Limited, Mumbai

In the result, both the appeal and cross objection are dismissed

ITA 5310/MUM/2025[2022-23]Status: DisposedITAT Mumbai05 Feb 2026AY 2022-23

Bench: Shri Saktijit Dey & Shri Arun Khodpiaito, Ward-1(3)(4) Wizcraft Entertainment Agency 5Th Floor, Aayakar Bhavan, Private Limited M. K. Road, Mumbai-400 020 1103, Morya Blue Moom Premises, Vs. Link Road, Andheri (W), Mumbai-400 053 Pan/Gir No. Aaacw 1107 H (Revenue) : (Assessee) & Co No. 36/Mum/2026 (Arising Out Of Ita No. 5310/Mum/2025) (Assessment Year: 2022-23) Wizcraft Entertainment Agency Ito, Ward-1(3)(4) Private Limited 5Th Floor, Aayakar Bhavan, 1103, Morya Blue Moom Premises, M. K. Road, Mumbai-400 020 Vs. Link Road, Andheri (W), Mumbai-400 053 Pan/Gir No. Aaacw 1107 H (Assessee) : (Revenue) Assessee By : Shri Siddharth Srivastava, Ca Revenue By : Shri Arun Kanti Datta – Cit Dr Date Of Hearing : 29.01.2026 Date Of Pronouncement : 05.02.2026 O R D E R Per Saktijit Dey: Captioned Appeal By The Department & Cross Objection By The Assessee, Arise Out Of Order Dated 30.06.2025 Passed By National Faceless Appeal Centre (‘Nfac’ For Short), Delhi, Pertaining To The Assessment Year (A.Y. For Short) 2022-23. 2

For Appellant: Shri Siddharth Srivastava, CAFor Respondent: Shri Arun Kanti Datta – CIT DR

Date of Hearing : 29.01.2026 Date of Pronouncement : 05.02.2026 O R D E R Per Saktijit Dey, Vice President: Captioned appeal by the Department and cross objection by the assessee, arise out of order dated 30.06.2025 passed by National Faceless Appeal Centre (‘NFAC’ for short), Delhi, pertaining to the assessment year ... being general ground, does not require adjudication. 17. In view of our decision in the department’s appeal, grounds raised in the cross objection having become academic, do not require adjudication at present. Hence, are kept open. 18. In the result, both the appeal and cross objection are dismissed. Order

Labdhi Logical Financial Solutions LLP, Dombivalt East, Thane vs. ITO 3(2), Kalyan

In the result, the appeal of the assessee is allowed

ITA 7635/MUM/2025[2013-14]Status: DisposedITAT Mumbai04 Feb 2026AY 2013-14

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokarlabdhi Logical Financial Ito-3(2), Solutions Llp 2Nd Floor, Rani B-22, Gao Devi Prasad, Vs. Mansion, Murbad Domvivali East, Thane, Road, Kalyan, Maharashtra-421 201 Maharashtra- 421 301 Pan/Gir No. Aaefl7209G (Applicant) (Respondent) Assessee By Shri Deepak Shah, Ld. Ar Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 28.01.2026 Date Of Pronouncement 04.02.2026

Section 144Section 144BSection 147Section 148Section 250Section 253(5)Section 68Section 69C

Your appellant craves for leave to add, amend or alter all or any of the grounds before or during hearing of these cross objections. 8. Before us, the assessee has primarily raised legal grounds challenging the validity of reassessment on the issue of limitation and on the ground that notices