Even though the assessee has not appealed against the order of a lower authority it may still defend such an order on the grounds decided against him if the grounds are otherwise in his favour. (AY. 2011-2012, 2014-2015, 2015-2016)
Dy. CIT v. Pacific Industries Ltd. (2019) 72 ITR 634 (Jodh.)(Trib.) Dy. CIT v. Pacific Leasing and Research Ltd. (2019) 72 ITR 634 (Jodh.)(Trib.)
S. 254(1) : Appellate Tribunal-Responded can depend the grounds, though no appeal id filed–Search and seizure–Jurisdiction issue. [S. 132, 153A, ITAT R. 27]