JUDGMENT K. B. Asthana, C.J. - Heard the learned counsel for the applicant and the learned counsel for the Revenue. 2. We think the following two questions arise from the Judgment of the Appellate Tribunal :- (1) Whether on the facts and in the circumstances of the case the Appellate Tribunal was justified in finding that the reopening of the assessment u/s 147(1)(a) was valid and sustainable in law ? (2) Whether on the facts and in the circumstances of the case the Appellate Tribunal was correct in finding that the applicant had failed to disclose the material which justified the reopening of the assessment of the year in question ? 3. Let the appellate Tribunal submit a statement of case to this Court. 4. The assessee will be entitled to Rs. 100/- as costs. 5. No costs are awarded in other connected cases.