The Tribunal held that the Commissioner (Appeals) jumped to the conclusion that the reopening was made based on the same information which was available to the Assessing Officer at the time of original assessment proceedings without discussing how the facts of the case fit into the ratio of the judicial precedents discussed by him. Nor had he discussed what information was available with the Assessing Officer at the time of original assessment proceedings and what information came to the knowledge of the Assessing Officer, enabling him to form an opinion that the income escaped assessment to tax. Since the findings of the Commissioner (Appeals) holding that the reopening was not valid had been reversed, the matter was to be remitted to the Commissioner (Appeals) for adjudication de novo. (AY.  2008-09)