2023 (8) TMI 391 - SCH - Income Tax

Reopening 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.

Summary

The Supreme Court dismissed the Special Leave Petitions after finding no merit in them. Delay was condoned, and pending application(s) were disposed of. Justices B. V. Nagarathna and Ujjal Bhuyan presided over the case.