https://www.taxtmi.com/caselaws?id=281157 Rule 27 permits a respondent to support the appealed order on a ground decided against it, including a legal challenge that could otherwise have been raised by appeal or cross-objection. Reassessment under sections 147 and 148 is invalid where the recorded reasons are vague, mechanical, and based only on Investigation Wing information without independent application of mind or tangible material establishing a live link to escaped income. Share application money cannot be treated as unexplained cash credit under section 68 where the assessee produces confirmations, PAN details, incorporation records, return filings, and bank evidence, and the department brings no positive material to prove unexplained income. en-us Fri, 08 Jan 2016 00:00:00 +0530 Wed, 05 Jun 2019 23:57:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=281157 Rule 27 permits a respondent to support the appealed order on a ground decided against it, including a legal challenge that could otherwise have been raised by appeal or cross-objection. Reassessment under sections 147 and 148 is invalid where the recorded reasons are vague, mechanical, and based only on Investigation Wing information without independent application of mind or tangible material establishing a live link to escaped income. Share application money cannot be treated as unexplained cash credit under section 68 where the assessee produces confirmations, PAN details, incorporation records, return filings, and bank evidence, and the department brings no positive material to prove unexplained income. Case-Laws Income Tax Fri, 08 Jan 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=281157