Court held that from Rule 27 of the Income-tax (Appellate Tribunal) Rules, 1963, it would be clear that an assessee in an appeal filed by the Department before the Tribunal is entitled to defend the order of the Commissioner (Appeals) on any of the grounds rejected by the Commissioner (Appeals). In fact, the rule does not specify any particular format in which the grounds can be raised before the Tribunal, and hence, an oral application is also permissible. However, a written application should be made, which would give the Department an opportunity to respond. The assessee cannot, however, raise a totally new ground before the Tribunal that was not raised by him before the Commissioner (Appeals) by virtue of this provision. Order of Tribunal allowing the grounds of reassessment is affirmed. (1999-2000, 2000-01)