Invoke Rule 27 of the Income-tax (Appellate Tribunal) Rules to raise a pure question of law relating to jurisdiction. Since such a ground goes to the root of the assessment, it can be entertained and adjudicated by the Tribunal. (AY. 2020 21)
ACIT v. Ramasubbu Minnalkodi (2025) 238 TTJ 337 (Chennai)(Trib.).
S. 253: Appellate Tribunal-Appeals-Respondent can raise jurisdictional ground without filing appeal or cross-objection [S. 254(1), ITAT R. 27]
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