https://www.taxtmi.com/caselaws?id=801181 Rule 27 allows a respondent that has neither appealed nor filed a cross-objection to defend an appellate order on a ground decided adversely, including a jurisdictional challenge to reassessment. Where alleged escaped income is based solely on search material and the year falls within the extended relevant assessment years under Section 153A, that provision's non obstante clause and mandatory language make it the exclusive assessment mechanism. If the extended-regime conditions, including the prescribed asset threshold, are met, recourse to Section 148 is without jurisdiction and the resulting reassessment is void ab initio. en-us Wed, 07 Oct 2026 00:00:00 +0530 Fri, 16 Oct 2026 05:20:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801181 Rule 27 allows a respondent that has neither appealed nor filed a cross-objection to defend an appellate order on a ground decided adversely, including a jurisdictional challenge to reassessment. Where alleged escaped income is based solely on search material and the year falls within the extended relevant assessment years under Section 153A, that provision's non obstante clause and mandatory language make it the exclusive assessment mechanism. If the extended-regime conditions, including the prescribed asset threshold, are met, recourse to Section 148 is without jurisdiction and the resulting reassessment is void ab initio. Case-Laws Income Tax Wed, 07 Oct 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801181