Tribunal admitted the issue of reassessment raised by orally in the appeal filed by the Revenue against the deletion of addition on merits. Reassessment is quashed on change of opinion.   The Tribunal held that the Respondent can raise the issue of validity of reassessment in an appeal filed by the Revenue. The issue can be raised by the Authorised representative orally at the time of hearing.    Rule  27 of the ITAT Rules, 1963, does not propose raising the objection in writing, the assessee-respondent is well within his right to raise the same orally. Referred, Peter Vaz v. CIT (2021) 322 CTR  121,204 DTR  376 (Bom)(HC), CIT v Dehati Co-operative Marketing-cum-Processing Society (1979) 9 CTR  32 3,  (1981) 130 ITR 504 (P&H)(HC)   Sanjay Sawhney v. PCIT (2020) 316 CTR  392,  192 DTR 105 (Delhi)(HC) (AY.  2010-11)