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    <description>Rule 27 of the ITAT Rules permits an assessee to raise a jurisdictional objection even if it was not pressed earlier, where the objection goes to the root of the reassessment. In reassessment proceedings, the addition must have a live nexus with the income for which reasons to believe were recorded. Where reopening was based on alleged undisclosed foreign bank account income, but the assessment instead brought to tax the minimum balance said to be needed to open the account, the addition was treated as beyond the scope of the recorded reasons and therefore unsustainable.</description>
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