Cross-objection under section 260A is not an independent right; respondent may only defend issues linked to the admitted question of law.

A cross-objection is not maintainable in an appeal under section 260A of the Income-tax Act, 1961 because that provision confines proceedings to substantial questions of law and contains no express right comparable to section 253(4). Section 260A(4) limits the respondent to contending that the appeal does not involve the formulated question, while section 260A(6) permits consideration only of issues tied to the admitted question of law. Section 260A(7) does not enlarge that limited scope. A respondent may therefore defend the impugned order only on grounds intrinsically connected with the admitted substantial question of law.

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Issues: Whether a cross-objection is maintainable in an appeal under section 260A of the Income-tax Act, 1961, and whether a respondent can invoke section 260A(6) and section 260A(7) to raise an independent challenge disconnected from the substantial question of law on which the appeal is admitted.

Analysis: The appeal under section 260A is a statutory remedy confined to substantial questions of law. Unlike section 253(4) of the Act, which expressly permits a memorandum of cross-objections before the Tribunal, section 260A contains no equivalent provision. The statutory text of section 260A(4) limits the respondent to arguing that the case does not involve the formulated substantial question of law, while section 260A(6) only enables the High Court to determine an issue not determined or wrongly determined by the Tribunal by reason of the question of law admitted in the appeal. The absence of an express legislative conferral of a right to file cross-objections, coupled with the limited scope of section 260A(6) and the qualified application of the Code under section 260A(7), indicates that a cross-objection cannot be treated as an independent substantive right in such proceedings.

Conclusion: A cross-objection is not maintainable in an appeal under section 260A of the Income-tax Act, 1961, save to the extent a respondent may defend the impugned order on grounds intrinsically connected with the substantial question of law already admitted.

Ratio Decidendi: In an appeal under section 260A of the Income-tax Act, 1961, the respondent has no independent statutory right to file a cross-objection unless the statute expressly provides for it; the respondent's challenge is confined to matters inseparably linked to the substantial question of law admitted in the appeal.

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