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Assessee Can Defend Order Under ITAT Rule 27 Even Without Filing Appeal or Cross-Objection in Section 147 Reassessment.

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....Reassessment u/s 147 - admission of grounds of appeal of the Assessee under Rule 27 of the ITAT Rules - an Assessee may not have appealed or filed a cross-objection but he is free to defend such order on all grounds including on any of the grounds decided against him by the authority whose order is otherwise in his favour....