Dismissing the appeal of the revenue the Court held that ; the matters of fact that were referred to in the Commissioner’s order under section 263 had been appropriately dealt with by the Tribunal which was satisfied that the order passed by the Commissioner was without basis. The Commissioner required the assessment to be reopened and directed the Assessing Officer to proceed in a particular manner. Some of the directions issued by the Commissioner indicated that the fresh assessment to be undertaken by the Assessing Officer was to only be a facile exercise as the quantum of addition in several cases were dictated to the Assessing Officer by the Commissioner. The Tribunal’s order reversing the Commissioner’s order did not warrant interference.