https://www.taxtmi.com/caselaws?id=275604 A cross-objection before the ITAT under section 253(4) read with Rule 22 is treated as having the same footing as an appeal and is not restricted to grounds already raised before the Assessing Officer or the first appellate authority. The Tribunal may admit a new legal ground where the relevant facts are already on record, the point is necessary for correct determination of tax liability, and there are bona fide reasons for not raising it earlier. On that basis, jurisdictional and procedural objections to the assessment, including challenge to satisfaction for section 153C proceedings and compliance with section 282A, were found maintainable without fresh factual enquiry, and the Revenue's preliminary objection was rejected. en-us Tue, 23 Sep 2014 00:00:00 +0530 Wed, 10 Oct 2018 09:06:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=275604 A cross-objection before the ITAT under section 253(4) read with Rule 22 is treated as having the same footing as an appeal and is not restricted to grounds already raised before the Assessing Officer or the first appellate authority. The Tribunal may admit a new legal ground where the relevant facts are already on record, the point is necessary for correct determination of tax liability, and there are bona fide reasons for not raising it earlier. On that basis, jurisdictional and procedural objections to the assessment, including challenge to satisfaction for section 153C proceedings and compliance with section 282A, were found maintainable without fresh factual enquiry, and the Revenue's preliminary objection was rejected. Case-Laws Income Tax Tue, 23 Sep 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=275604