The Tribunal decided the case of the two individuals and concluded that the income could not be taxed in their hands in the absence of any material on record to show that there was any undisclosed income in their hands. There was neither any finding nor any direction of the Tribunal regarding undisclosed income of the assessee-company. There was no finding or direction of the Tribunal allowing the Assessing Officer to bring to tax  in any manner whatsoever. In both the reasons recorded for reopening and in the assessment order there was no reference to any seized material that could substantiate the addition made by the Assessing Officer. Therefore, the Assessing Officer is  not justified in reopening and adding the amount as undisclosed income in the hands of the assessee.(AY.2007-08)