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Re-opening of the assessment / re-assessment u/s 147 - The borrowed opinion also being conspicuously absent in the instant case subsequent events also disclosing certain transactions attributable to the assessee having been unearthed during the course of search proceedings and the statement of the assessee himself disclosing the admission with regard to the said transaction, it cannot be gainsaid by the petitioner / assessee that such commencement of re-assessment proceeding is without jurisdiction or jurisdictional error having been committed by the authorities. - Petition dismissed - HC