Allowing the appeal  of the assessee the Court held that the Tribunal’s findings amounted to supplying reasons in respect of the Assessing Officer’s order, on aspects, which were not expressly reflected in the assessment order. The Tribunal not only went into the merits of the Commissioner’s order, which could be considered as only indicative of what was missed out by the Assessing Officer, but also recorded its findings. It proceeded to hold that amounts due to drawbacks/incentives and foreign exchange fluctuations were to be considered and had been considered by the Assessing Officer but not the Commissioner. As a matter of fact, the Assessing Officer had recorded no observation or findings on those issues, nor the issue of the loans, which the assessee had received, or the amounts claimed by him as interest. Given those matters of record, it was difficult to validate the Tribunal’s approach reading into the Assessing Officer’s order, reasons which were not there. The Tribunal’s order itself disclosed that the Assessing Officer did not investigate into the question of advances given to others, having regard to the assessee’s claim for having taken loans, for which interest expenditure was claimed. The duty of the Commissioner was to record why revision was warranted. The Tribunal’s jurisdiction was not to rewrite the Assessing Officer’s order and improve upon it. The orders of the Tribunal were unsustainable and thus were to be set aside. ( AY. 2011-12, 2012-13