Assessee challenged reassessment proceedings contending that mere audit objection could not form basis to reopen completed assessment and Assessing Officer had no reason to believe to reopen assessment and reopening amounted to change of opinion. Commissioner (Appeals) dismissed assessee’s appeal. On appeal, Tribunal did not render any specific finding on assumption of jurisdiction by Assessing Officer. On appeal the Court held that Tribunal ought to have adjudicated all grounds raised by assessee, that is, whether reopening was valid in law and whether there were materials in hands of Assessing Officer for reopening assessment and, thus, matter was restored to Tribunal. (AY. 2011-12)