Rule 27 of ITAT Rules :HIGH COURT OF DELHI on May 18, 2020 hold that Not having filed a cross objection, even when the appeal was preferred by the Revenue, it does not mean that an inference can be drawn that the assessee had accepted the findings in part of the final order, that was decided against him. Therefore, when the Revenue filed an appeal before the ITAT, the assessee was entitled under law to defend the same and support the order in appeal on any of the grounds decided against it. SANJAY SAWHNEY vs. PCIT AY 2008-09