https://www.taxtmi.com/caselaws?id=326439 Rule 27 of the ITAT Rules allows a respondent to support the impugned order on a legal ground decided against it, without filing a cross appeal or cross objection, where the point can be decided on the existing record; here, the assessee could raise limitation under section 275(1)(a), but the penalty order was still within time because it was passed within six months from the end of the month in which the quantum order was received. Penalty under section 271(1)(c) was also held unsustainable where the assessment was finally made on book profits under section 115JB and the alleged concealment did not affect the tax liability determined. en-us Wed, 02 Mar 2016 00:00:00 +0530 Fri, 15 Apr 2016 11:17:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=326439 Rule 27 of the ITAT Rules allows a respondent to support the impugned order on a legal ground decided against it, without filing a cross appeal or cross objection, where the point can be decided on the existing record; here, the assessee could raise limitation under section 275(1)(a), but the penalty order was still within time because it was passed within six months from the end of the month in which the quantum order was received. Penalty under section 271(1)(c) was also held unsustainable where the assessment was finally made on book profits under section 115JB and the alleged concealment did not affect the tax liability determined. Case-Laws Income Tax Wed, 02 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=326439