“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

DCIT, Central Circle-2, Visakhapatnam vs. Vamsee Krishna Kuppannagari, Parvathipuram

In the result, all the six appeals of the Revenue are dismissed

ITA 57/VIZ/2025[2013-14]Status: DisposedITAT Visakhapatnam08 Apr 2025AY 2013-14

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. Nos. 57, 58, 59, 60, 61 & 62/Viz/2025 (िनधा"रण वष" / Assessment Year : 2013-14, 2012-13, 2014-15, 2015-16, 2016-17 & 2018-19) Deputy Commissioner Of Income Vs. Vamsee Krishna Kuppannagari, Tax, Parvathipuram. Central Circle-2, Pan: Aivpk2261L Visakhapatnam. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) C.O. Nos.9, 10, 11, 12, 13 & 14/Viz/2025 (In आयकर अपील सं./ I.T.A. Nos. 57, 58, 59, 60, 61 & 62/Viz/2025) (िनधा"रण वष" / Assessment Year : 2013-14, 2012-13, 2014-15, 2015-16, 2016-17 & 2018-19) Vamsee Krishna Kuppannagari, Vs. Deputy Commissioner Of Parvathipuram. Income Tax, Pan: Aivpk2261L Central Circle-2, Visakhapatnam. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Assessee By : Smt. A. Aruna ""याथ" क" ओर से / Revenue By : Dr. Aparna Villuri, Sr. Ar सुनवाई क" तारीख / Date Of Hearing : 07/04/2025 घोषणा क" तारीख/Date Of : 08/04/2025 Pronouncement

For Appellant: Smt. A. ArunaFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 1

61/Viz/2025 2016-17 26/11/2024 ITBA/APL/S/250/2024- 147 25/1070656473(1) 6. 62/Viz/2025 2018-19 27/11/2024 ITBA/APL/S/250/2024- 147 25/1070693116 (1) The assessee has also raised Cross Objections (C.O. Nos.9, 10, 11, 12, 13 & 14/Viz/2025). Since the Revenue’s appeals and Cross Objections are connected and pertain to the same assessee, all these appeals ... dismissed as not maintainable considering the low tax effect, the adjudication of Cross Objections filed by the assessee in the respective Assessment Years becomes infructuous. Accordingly, the Cross Objections filed by the assessee are dismissed. 7. In the result, appeals filed by the Revenue are dismissed and the Cross Objections

Assistant Commissioner of Income Tax, Central Circle-2, Trichy vs. Subramanian Paramasivam, Karur

Appeal is dismissed, thereby the CO filed

ITA 2348/CHNY/2024[2018-19]Status: DisposedITAT Chennai08 Apr 2025AY 2018-19

Bench: Shri Manu Kumar Giri & Shri Jagadish

For Appellant: Mr. N.V.Balaji, Advocate

Section 132Section 143(3)Section 144Section 153CSection 154

seratttare/Assessee by : | Mr. N.V.Balaji, Advocate aAarestarra/Date of hearing : | 28.01.2025 armartrarra /Date of Pronouncement | : | 08.04.2025 wea / ORDER PER MANU KUMAR GIRI, JM: The appeal and cross objection are arising out of the order of the Commissioner of Income tax (Appeals) — 19, Chennai [hereinafter referred

Income Tax Officer 23 3 6, Piramal Chambers vs. Rahul Hariprasad Tibrewal, Mumbai

ITA 430/MUM/2025[2017-18]Status: DisposedITAT Mumbai08 Apr 2025AY 2017-18

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SMT RENU JAUHRI (Accountant Member)

For Appellant: Shri Dharmesh ShahFor Respondent: Shri R. R. Makwana

Section 144BSection 147Section 148Section 148ASection 250

Date Conclusion of hearing : 12.03.2025 Pronouncement of order : 08.04.2025 O R D E R Per Rahul Chaudhary, Judicial Member: 1. The present appeal and cross objection pertains to Assessment Year 2017-2018. The Revenue has preferred appeal against the ITA No. 430/Mum/2025 & C.O. No. 63/Mum/2025 Assessment Year 2017-2018 order ... Order, dated 22/05/2023, passed under Section 147 read with Section 144B of the Act, for the Assessment Year 2017-2018. The Assessee has filed cross objection. 2. The relevant facts in brief are that notice under Section 148 of the Act (old regime) was issued to the Assessee

Assistant Commissioner of Income Tax, Central Circle-1, Ranchi vs. Shri Kamal Bhushan, Ranchi

In the result, appeal filed by the revenue is dismissed and the cross objection of the assessee is allowed

ITA 36/RAN/2021[2014-15]Status: DisposedITAT Ranchi07 Apr 2025AY 2014-15

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

Section 139Section 153ASection 271Section 271(1)(c)Section 274

Date of hearing 20/03/2025 Date of pronouncement 28/03/2025 O R D E R PER: BENCH 1. The appeal by the Revenue and Cross Objection (CO) therein by the assessee are directed against the order of learned Commissioner of Income tax (Appeals), Patna-3, Patna [‘ld. CIT(A)’ for short] dated ... before the date of search and as such, the finding of the above cited case is not applicable. 4. For that other grounds for cross-objection in detail will be argued at the time of hearing. 3. Facts of the case, in brief, are that a search and seizure operation

DCIT-CC(5), Mumbai vs. Larsen & Toubro Limited, Mumbai

In the result, for A.Y. 2015-16, appeal by the revenue is dismissed and cross objection by the assessee is allowed

ITA 5745/MUM/2024[2014-15]Status: DisposedITAT Mumbai07 Apr 2025AY 2014-15

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri J.D. Mistry, Sr. Advocate and Shri Ronak Joshi, CAFor Respondent: Dr. K.R. Subhash, CIT DR and Shri Ram Krishn Kedia, Sr. DR

Section 147Section 148

others Larsen & Toubro Limited, AY 2014-15 & 2015-16 ITBA/APL/S/250/2024-25/1067371868(1), dated 06.08.2024 & ITBA/APL/S/250/2024-25/1067371345(1), dated 06.08.2024 and Cross Objection filed by the assessee against the order of Ld. CIT(A)-53, Mumbai vide order no. ITBA/APL/S/250/2024-25/1067371345(1), dated 06/08/2024 passed against the assessment orders by Asst. Commissioner of Income ... gratification and same were reimbursed in form of variation bill raised by L & T.” 2.2. Grounds of objections raised by the assessee in its Cross Objection No.282/Mum/2024 for A.Y.2015-16 are reproduced hereunder:- “1. On the facts and circumstances of the case and for various propositions in law, the Ld. Commissioner

DCIT-CC- 5(4), Mumbai vs. Larsen & Toubro Limited, Mumbai

In the result, for A.Y. 2015-16, appeal by the revenue is dismissed and cross objection by the assessee is allowed

ITA 5743/MUM/2024[2015-16]Status: DisposedITAT Mumbai07 Apr 2025AY 2015-16

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri J.D. Mistry, Sr. Advocate and Shri Ronak Joshi, CAFor Respondent: Dr. K.R. Subhash, CIT DR and Shri Ram Krishn Kedia, Sr. DR

Section 147Section 148

Sanjeeta Chatterjee, Dubai vs. DCIT Intl. Taxation, Noida

ITA 2242/DEL/2024[2015-16]Status: DisposedITAT Delhi07 Apr 2025AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year: 2011-12 Dcit, Vs Geemed Promoters P. Ltd., Central Circle-28, F-6, Second Floor, New Delhi. Vijay Chowk, Laxmi Nagar, New Delhi – 110 092. Pan: Aaecg1614P Co No.114/Del/2018 (Ita No.2242/Del/2018) Assessment Year: 2011-12 Geemed Promoters P. Ltd., Vs. Dcit, F-6, Second Floor, Central Circle-28, Vijay Chowk, New Delhi. Laxmi Nagar, New Delhi – 110 092. Pan: Aaecg1614P (Appellant) (Respondent) Assessee By : Shri Sachin Jain, Advocate Revenue By : Shri Om Parkash, Sr. Dr Date Of Hearing : 07.05.2025 Date Of Pronouncement : 28.05.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Revenue Against The Order Dated 15.01.2018 Of The Commissioner Of Income-Tax (Appeals)-29, New Delhi Co No.114/Del/2018 (Hereinafter Referred To As The Ld. First Appellate Authority Or ‘The Ld. Faa’, For Short) In Appeal No.298/16-17/Cit(A)-29 Arising Out Of The Appeal Before It Against The Order Dated 19.03.2014 Passed U/S 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) By The Acit, Central Circle-28, New Delhi (Hereinafter Referred To As The Ld. Ao). The Assessee Has Filed Cross Objection. 2. The Revenue Has Taken The Following Grounds Of Appeal:- “1. That On The Facts & In The Circumstances Of The Case, The Ld. Cit(A) Has Erred In Deleting The Addition Of Rs. 10 Crore On Account Of (Paid - Up Share Capital, Share Premium & Security Premium) Credited In Its Books Of Accounts Ignoring The Fact That The Assessee Had Not Discharged Its Primary Onus To Establish The Identity & Creditworthiness Of The Creditors & Genuineness Of The Transaction During Assessment Proceedings.” 2. The Appellant Craves Leave To Add, Alter Or Amend Any/All Of The Grounds Of Appeal Before Or During The Course Of The Hearing Of The Appeal.”

For Appellant: Shri Sachin Jain, AdvocateFor Respondent: Shri Om Parkash, Sr. DR

Section 132Section 143(3)Section 153A

hereinafter referred as ‘the Act’) by the ACIT, Central Circle-28, New Delhi (hereinafter referred to as the Ld. AO). The assessee has filed Cross Objection. 2. The Revenue has taken the following grounds of appeal:- “1. That on the facts and in the circumstances of the case ... alter or amend any/all of the grounds of appeal before or during the course of the hearing of the appeal.” 3. The grounds of Cross Objections read as under:- “1. The learned CIT(A), erred in confirming the ad hoc addition of Bank deposit of Rs 1,70,000/- (Rupees

Circle-4(1)(1), Ahmedabad vs. Sameep Fabrics Private Limited, Ahmedabad

In the result, the appeal filed by the Department is dismissed for A

ITA 2020/AHD/2024[2019-20]Status: DisposedITAT Ahmedabad04 Apr 2025AY 2019-20

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Gaurav Nahta & Shri Vihar Soni, A.RsFor Respondent: Smt. Trupti Patel, Sr. DR

Section 131Section 132Section 271(1)(c)

short “Ld. CIT(A)”), National Faceless Appeal Center (in short “NFAC”), Delhi vide orders dated 23.09.2024 passed for A.Ys. 2013 & 2019-20 and the Cross Objections filed by the assessee against the appeals filed by the Department. ITA Nos. 2017&2020/Ahd/2024 & C.O. Nos. 01&04/Ahd/2025 DCIT vs. Sameep Fabrics ... 01/Ahd/2025 (A.Y. 2013-14) 11. Before us, the Counsel for the assessee submitted that he shall not be pressing of his Cross Objection No. 01/Ahd/2025 for A.Y. 2013-14. Accordingly, the Cross Objection filed by the assessee for A.Y. 2013-14 is being dismissed as not pressed

DCIT, Circle-4(1)(1), Ahmedabad, Vejalpur vs. Sameep Fabrics Private Limited, Piplaj Ahmedabad

In the result, the appeal filed by the Department is dismissed for A

ITA 2017/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad04 Apr 2025AY 2013-14

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Gaurav Nahta & Shri Vihar Soni, A.RsFor Respondent: Smt. Trupti Patel, Sr. DR

Section 131Section 132Section 271(1)(c)

M/S. Seth B D Goyal Charitable Trust, Kolkata vs. I.T.O. Ward - 1(3), Exemption, Kolkata

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2267/KOL/2024[2020-2021]Status: DisposedITAT Kolkata04 Apr 2025AY 2020-2021

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 11Section 143(1)Section 143(1)(a)Section 250

placed on record, CBDT Instruction and circulars and the applicable provisions of law, we are of the considered view to allow the grounds of Cross objection raised by the assessee and dismiss the grounds raised by the revenue in its appeal. Accordingly, Cross Objection by the assessee is allowed

DCIT(CC)-8(3), Mumbai vs. Manoj Naginlal Jain, Mumbai

In the result, all the appeals filed by the Revenue and all the cross objections filed by the assessee are dismissed

ITA 6812/MUM/2024[2018-19]Status: DisposedITAT Mumbai04 Apr 2025AY 2018-19

Bench: Shri B.R. Baskaran & Shri Narender Kumar Choudhry

For Appellant: Shri Suchek AnchaliyaFor Respondent: Ms. Sanyogita Nagpal, CIT-DR

Section 10(38)Section 153A

Hearing : 19-03-2025 Date of Pronouncement : 04-04-2025 O R D E R PER BENCH : The appeals of the Revenue and the cross objections filed by the assessee are directed against the orders passed by the Ld CIT(A)-50, 2 Manoj Naginlal Jain, (batch) Mumbai and they ... years under consideration were deleted by Ld CIT(A) and hence the revenue is challenging the orders passed by him. 3. In the cross objections, the assessee has raised certain legal grounds besides supporting the orders passed by Ld CIT(A). 4. The facts relating to the case are discussed

DCIT(CC)-8(3), Mumbai vs. Manoj Naginlal Jain, Mumbai

In the result, all the appeals filed by the Revenue and all the cross objections filed by the assessee are dismissed

ITA 6811/MUM/2024[2019-20]Status: DisposedITAT Mumbai04 Apr 2025AY 2019-20

Bench: Shri B.R. Baskaran & Shri Narender Kumar Choudhry

For Appellant: Shri Suchek AnchaliyaFor Respondent: Ms. Sanyogita Nagpal, CIT-DR

Section 10(38)Section 153A

DCIT(CC)-8(3), Mumbai vs. Manoj Naginlal Jain, Mumbai

In the result, all the appeals filed by the Revenue and all the cross objections filed by the assessee are dismissed

ITA 6810/MUM/2024[2015-16]Status: DisposedITAT Mumbai04 Apr 2025AY 2015-16

Bench: Shri B.R. Baskaran & Shri Narender Kumar Choudhry

For Appellant: Shri Suchek AnchaliyaFor Respondent: Ms. Sanyogita Nagpal, CIT-DR

Section 10(38)Section 153A

DCIT(CC)-8(3), Mumbai vs. Manoj Naginlal Jain, Mumbai

In the result, all the appeals filed by the Revenue and all the cross objections filed by the assessee are dismissed

ITA 6809/MUM/2024[2013-14]Status: DisposedITAT Mumbai04 Apr 2025AY 2013-14

Bench: Shri B.R. Baskaran & Shri Narender Kumar Choudhry

For Appellant: Shri Suchek AnchaliyaFor Respondent: Ms. Sanyogita Nagpal, CIT-DR

Section 10(38)Section 153A

DCIT(CC)-8(3), Mumbai vs. Manoj Naginlal Jain, Mumbai

In the result, all the appeals filed by the Revenue and all the cross objections filed by the assessee are dismissed

ITA 6808/MUM/2024[2017-18]Status: DisposedITAT Mumbai04 Apr 2025AY 2017-18

Bench: Shri B.R. Baskaran & Shri Narender Kumar Choudhry

For Appellant: Shri Suchek AnchaliyaFor Respondent: Ms. Sanyogita Nagpal, CIT-DR

Section 10(38)Section 153A

DCIT(CC)-8(3), Mumbai vs. Manoj Naginlal Jain, Mumbai

In the result, all the appeals filed by the Revenue and all the cross objections filed by the assessee are dismissed

ITA 6807/MUM/2024[2016-17]Status: DisposedITAT Mumbai04 Apr 2025AY 2016-17

Bench: Shri B.R. Baskaran & Shri Narender Kumar Choudhry

For Appellant: Shri Suchek AnchaliyaFor Respondent: Ms. Sanyogita Nagpal, CIT-DR

Section 10(38)Section 153A

DCIT(CC)-8(3), Mumbai vs. Manoj Naginlal Jain, Mumbai

In the result, all the appeals filed by the Revenue and all the cross objections filed by the assessee are dismissed

ITA 6806/MUM/2024[2014-15]Status: DisposedITAT Mumbai04 Apr 2025AY 2014-15

Bench: Shri B.R. Baskaran & Shri Narender Kumar Choudhry

For Appellant: Shri Suchek AnchaliyaFor Respondent: Ms. Sanyogita Nagpal, CIT-DR

Section 10(38)Section 153A

M/S Fluor Danier India Pvt. Ltd., New Delhi vs. DCIT, New Delhi

In the result, appeal of the assessee in ITA No

ITA 2696/DEL/2013[2008-09]Status: DisposedITAT Delhi04 Apr 2025AY 2008-09

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2014-15] Dcit, Vs Reliance Ritu Kumar Pvt.Ltd. Central Circle-4, (Earlier Known As Ritika New Delhi Pvt.Ltd.), B-38, Sagar Apartment, 6, Tilak Marg, New Delhi-110001. Pan-Aabcr5510N Appellant Respondent

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

Sns Constructions P.Ltd, Panipat vs. ITO, Ward-4, Panipat

In the result, the appeal of the revenue is dismissed and the CO of the 7

ITA 4013/DEL/2019[2014-15]Status: DisposedITAT Delhi03 Apr 2025AY 2014-15

Bench: Shri C. N. Prasad & Shri M. Balaganeshincome Tax Officer, Vs. Anil Kumar, Ward-1(1), J-10, South City-1, Gurgaon Gurgaon, Haryana (Appellant) (Respondent) Pan: Aampk9521G Co No. 88/Del/2024 (Ita No. 4013/Del/2024) (Assessment Year: 2014-15) Anil Kumar, Vs. Income Tax Officer, J-10, South City-1, Ward-1(1), Gurgaon, Haryana Gurgaon (Appellant) (Respondent) Pan: Aampk9521G

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri Ajay Kumar Arora, Sr. DR

Section 10(38)Section 115BSection 133ASection 143(3)Section 144Section 147Section 148Section 44ASection 69

which we do not find any infirmity. Since, the reassessment is quashed, the adjudication of other grounds 6. raised by the assessee in his cross objection becomes academic in nature and hence, they are left open. In the result, the appeal of the revenue is dismissed

Assistant Commissioner of Income Tax, Haldwani vs. Delta Power Solutions (India) Pvt. Ltd., (Now), Delta Electronics India Pvt. Ltd., Gurgaon

Accordingly. This Revenue’s appeal ITA Nos. 5543/Del/2018 is partly allowed for statistical purposes

ITA 3/DDN/2024[2013-14]Status: DisposedITAT Dehradun02 Apr 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2013-14 Vs. M/S. Dcit, Delta Power Solution Circle-1, (India) Pvt. Ltd., Haldwani Plot No. 38, Phase-1, Sector-5, Iie, Pantnagar, Rudrapur, Distt. Us Nagar, Udham Singh Nagar, Uttarakhand Pan: Aaccd5896N (Appellant) (Respondent) With C.O. No. 38/Del/2019 [Arise Out Of Ita No.5543/Del/2018] Assessment Year: 2013-14 Vs. Dcit, Delta Power Solution (India) Pvt. Ltd., Circle-1, Plot No. 38, Phase-1, Sector- Haldwani 5, Iie, Pantnagar, Rudrapur, Distt. Us Nagar, Udham Singh Nagar, Uttarakhand Pan: Aaccd5896N (Appellant) (Respondent) With Assessment Year: 2013-14 Vs. Delta Power Solution (India) Acit, Haldwani Pvt. Ltd. (Now, Delta Electronics India Pvt. Ltd.) Plot No. 43, Sector-35, Hsiidc, Gurgaon Pan: Aaccd5896N (Appellant) (Respondent)

Section 143(3)

single assessee herein, M/s. Delta Power Solutions India Pvt. Ltd. These Revenue’s twin appeals ITA Nos.5543/Del/2018 and 3/DDN/2024 (duplicate file) with assessee’s cross-objection in the former case C.O. No. 38/Del/2019, arise against the CIT(A), Haldwani’s order dated 23.05.2018 passed in case no. 10216/CIT(A)/HLD/2016-17 ... partly allowed for statistical purposes and it’s latter appeal ITA No. 3/DDN/2024 is dismissed as a “duplicate” file and the assessee’s cross objections C.O. No. 38/Del/2019 is dismissed as not pressed, in above terms. A copy of this common order be placed in the respective case files. Order