https://www.taxtmi.com/caselaws?id=467856 Rule 27 of the ITAT Rules permits a respondent to support a favourable order on grounds decided against it below, but only to sustain that order and not to enlarge the relief or alter the appellant's position. On the facts, the assessee could not press grounds that had not been specifically decided against it, while the ground relating to the seized material and the assessment year was considered only to the extent it supported the existing relief. The deletion of the addition was sustained because the seized material showed the cash payment related to a different financial year, so the addition could not be brought to tax in the year under appeal. en-us Fri, 09 Jan 2026 00:00:00 +0530 Mon, 06 Apr 2026 19:07:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467856 Rule 27 of the ITAT Rules permits a respondent to support a favourable order on grounds decided against it below, but only to sustain that order and not to enlarge the relief or alter the appellant's position. On the facts, the assessee could not press grounds that had not been specifically decided against it, while the ground relating to the seized material and the assessment year was considered only to the extent it supported the existing relief. The deletion of the addition was sustained because the seized material showed the cash payment related to a different financial year, so the addition could not be brought to tax in the year under appeal. Case-Laws Income Tax Fri, 09 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467856