Held that   the Assessing Officer had followed one part of the direction of the Commissioner (Appeals) but not the other part regarding reopening of the assessment or taxability of the correct assessment year. The Assessing Officer failed to give effect to the appeal and the Commissioner (Appeals) mechanically sustained the finding of the Assessing Officer without giving any reason why reopening of the assessment for the purpose of taxability was not given effect to. Hence, the finding of the Commissioner (Appeals) could not be sustained and the order was set aside. The Assessing Officer was directed to give effect to the order of the Commissioner (Appeals) in accordance with law. (AY.  2011-12)