https://www.taxtmi.com/caselaws?id=36880 In a tax appeal, the Tribunal's appellate jurisdiction is limited to the subject-matter of the appeal, but that subject-matter must be read in a practical and interconnected way. A respondent may support the first appellate order under Rule 27 on a ground decided against it, provided the contention is used only to sustain the order and does not worsen the appellant's position. Where disputed share profits and the related interest allowance formed one connected assessment controversy, the Department could argue that the interest relief could not stand if the share transactions were treated as bogus. en-us Tue, 13 Nov 1979 00:00:00 +0530 Thu, 25 Mar 2010 11:51:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=36880 In a tax appeal, the Tribunal's appellate jurisdiction is limited to the subject-matter of the appeal, but that subject-matter must be read in a practical and interconnected way. A respondent may support the first appellate order under Rule 27 on a ground decided against it, provided the contention is used only to sustain the order and does not worsen the appellant's position. Where disputed share profits and the related interest allowance formed one connected assessment controversy, the Department could argue that the interest relief could not stand if the share transactions were treated as bogus. Case-Laws Income Tax Tue, 13 Nov 1979 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=36880