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2011 (11) TMI 437 - HC - Income TaxRejection of the alternative contentions of assessee on the ground of limitation - assessee had raised an alternative contention of exemption u/s 11 before the CIT (A) - CIT (A) decided in favor of assessee and did not examine alternative contention on merits – Held that:- When the Revenue had carried the CIT (A)’s order before the Tribunal, it was open for the assessee to support the order on all grounds including those which may not have been accepted or examined by the CIT (A). For this purpose, cross-objection was not necessary. In that view of the matter, the Tribunal not entertaining such cross-objection on the ground of delay, would not be fatal to the assessee’s contention. It is clarified that if the Revenue’s appeal before the Court is entertained further, it would be open for the assessee to support the orders in its favor on all grounds.
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