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2023 (8) TMI 391 - SC ORDERReopening of assessment u/s 147 - unexplained cash deposits - scope of term change of opinion - as per HC just because the Appellate Authority has the power to modify an assessment order with regard to a source of income that has not been considered during assessment proceedings does not mean that the jurisdiction of the authorities u/s 148 would be excluded when the issue involved in the proceeding u/s 148 is not the same as that being considered u/s 251 - HELD THAT:- We do not find any merit in the Special Leave Petitions. Special Leave Petitions are dismissed.Pending application(s) shall stand disposed of.
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