https://www.taxtmi.com/caselaws?id=772098 The ITAT Chennai held that reassessment proceedings under section 147 were validly initiated despite the notice being issued under section 148 on 27.04.2021, following SC precedent in Union of India v. Ashish Agarwal that such notices are deemed issued under substituted section 148A. The limitation objection was rejected. Regarding foreign income addition, the matter was remanded to the AO for fresh examination as the assessee provided documentary evidence before the Tribunal showing income pertained to previous financial year, which lower authorities had no opportunity to verify. Appeal partly allowed for statistical purposes. en-us Fri, 28 Mar 2025 00:00:00 +0530 Wed, 04 Jun 2025 08:40:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772098 The ITAT Chennai held that reassessment proceedings under section 147 were validly initiated despite the notice being issued under section 148 on 27.04.2021, following SC precedent in Union of India v. Ashish Agarwal that such notices are deemed issued under substituted section 148A. The limitation objection was rejected. Regarding foreign income addition, the matter was remanded to the AO for fresh examination as the assessee provided documentary evidence before the Tribunal showing income pertained to previous financial year, which lower authorities had no opportunity to verify. Appeal partly allowed for statistical purposes. Case-Laws Income Tax Fri, 28 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772098