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Ito (International Taxation)-1, ... vs Ratan Kumar Ingu, Hyderabad on 4 September, 2025 cites

B.R. Bamasi vs Commissioner Of Income-Tax, Bombay ... on 16 February, 1970

6. Thus, Rule 27 of the ITAT Rules, 1963 contemplates that the respondent can support the order of the learned CIT (A) against which the other party has filed the appeal on any of the ground decided against him. The scope of raising a plea under Page 8 of 22 ITA No 573 of 2025 Ratan Kumar Ingu Rule 27 of the ITAT Rules to defend against the appeal filed by the other party and thereby if the issue raised by the respondent is decided in favour of the respondent may lead to failure of the appeal filed by the other party. Therefore, even if the issue which is raised by the respondent assessee is decided in favour of the assessee holding that the reopening of the assessment is not valid and liable to be quashed, the impugned order of the learned CIT (A) would stand and will have full effect in so far as it is against the Revenue, but the assessee will succeed only to the extent that the appeal filed by the Revenue would fail. The Hon'ble Bombay High Court in the case of B.R. Bamasi vs. CIT reported in 83 ITR 223 has discussed the scope of Rule 27 of the ITAT Rules, 1963 as under:
Bombay High Court Cites 18 - Cited by 58 - Full Document

Smt. Madhu Soni vs Assistant Commissioner Of Income Tax on 1 September, 2015

In support of his contention, he has relied upon the decision of the Delhi Bench of the Tribunal in case of Smt. Madhu Gangwani v. Assistant Commissioner of Income- tax, reported in 111 Taxmann.com 30. The learned Counsel for the assessee has further submitted that the reopening is also not valid as the Assessing Officer as the Assessing Officer has not followed the procedure before issuing notice u/s 148 of the Act on 30/03/2021 as prescribed in the CBDT Instruction No.14/2013 dated 23/09/2013. Thus, the learned Counsel for the assessee has submitted that once the reopening of the assessment is not valid and liable to be quashed, then the appeal of the Revenue is also liable to be dismissed.
Chattisgarh High Court Cites 7 - Cited by 0 - Full Document

The Deputy Commissioner Of Income Tax ... vs Kalinga Institute Of Industrial ... on 1 May, 2023

In support of his Page 6 of 22 ITA No 573 of 2025 Ratan Kumar Ingu contention, he has relied upon the judgment of the Hon'ble Supreme Court in the case of Dy.CIT vs. Kalinga Institute of Industrial Technology dated 01/03/2023 in Special Leave Petition No.29304 of 2019 and submitted that the Hon'ble Supreme Court has reversed the order of the Hon'ble High Court whereby the assessment order was quashed on the ground that the jurisdictional Assessing Officer has not adjudicated upon the return. The jurisdiction has been changed after the return was filed. Therefore, once the assessee has not disputed the jurisdiction of the Assessing Officer, then the time limit as prescribed u/s 124(3) of the Act, the assessee cannot question the jurisdiction of the Assessing Officer.
Supreme Court - Daily Orders Cites 2 - Cited by 0 - Full Document
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