Judgment :- 1. The Income Tax Appellate Tribunal, Cochin Bench (hereinafter called the Tribunal) has referred to this Court under S.256 (1) of the Income Tax Act, 1961 for short, the Act the following question of law as arising out of its order dated 26th April, 1977 in I. T. A. No. 355/Coch/1974-75, "Whether on the facts and circumstances of the case, the reopening of the assessment for the assessment year 1968-69 under S.147 (b) of the Income Tax Act, 1961 was not valid?" The assessee is a public limited company-The Kerala State Industrial Development Corporation Ltd. incorporated with the object of supplying information to entrepreneurs about the possibilities of starting Industries in Kerala State, financing the same by share participation, underwriting of shares, guaranteeing and advancing of loans etc. It gets remuneration for the services rendered by it. 2. For the assessment year 1968-69, the assessee filed a return disclosing an income of Rs. 9,20,800/-. In so doing it had claimed deduction of Rs. 32,978/- being the share of grant given by it to the Labour and Industrial Bureau. The Income Tax Officer allowed the said deduction and completed the assessment on 24 91968. Subsequently he came to know that the Appellate Assistant Commissioner while dealing with an appeal arising out of the assessment made on the assessee-company for the assessment year 1970-71 had held that such grant made to the Labour and Industrial Bureau could not be considered as allowable deduction. In view of this the Income Tax Officer initiated proceedings for reopening the assessment under S.147(b) of the Act, and issued a notice to the assessee on 9-3-1972 requiring it to file a return of its income for the assessment year in question The assessee contended inter alia before the Income Tax Officer that there was no omission or failure on its part to disclose all the information and that the initiation of proceedings under S.147(b) was not valid. The Income Tax Officer overruled the objection. He had already reopened the assessment for the assessment year 1967-68 on the identical ground and had completed the revised assessment for that assessment year by his order dated 15 3 1973. Likewise he completed the revised assessment for the assessment year 1968-69 by his order dated 16 21974 by adding back the amount of Rs. He had already reopened the assessment for the assessment year 1967-68 on the identical ground and had completed the revised assessment for that assessment year by his order dated 15 3 1973. Likewise he completed the revised assessment for the assessment year 1968-69 by his order dated 16 21974 by adding back the amount of Rs. 32,978/- as the sum representing the grant made by the assessee to the Labour and Industrial Bureau in respect of which a deduction had been originally allowed The assessee took up the matter in appeal before the Appellate Assistant Commissioner who confirmed the revised assessment made by the Income Tax Officer. On a second appeal being filed by the assessee before the Tribunal, the Tribunal took the view that the decision of the Appellate Assistant Commissioner for the assessment year 1970-1971 holding that no deduction could be allowed in respect of the grant made by the assessee to the Labour and Industrial Bureau could not constitute 'information' on the basis of which proceedings under S 147(b) could be validly initiated by the Income Tax Officer especially because the said decision of the Appellate Assistant Commissioner had not become final at the relevant time. In this view the Tribunal considered it unnecessary to go into the further question raised before it on behalf of the assessee that the reassessment was barred by time. 3. An identical question as to whether the decision of the Appellate Assistant Commissioner rendered in relation to the assessment year 1970-71 holding that no deduction could be allowed in respect of the grant made by the assessee to the Labour and Industrial Bureau would constitute information in the possession of the Income Tax Officer for the purposes of S.147(b) came up before this Court in LT R. No. 20 of 1977 which arose out of the decision rendered by the Tribunal with respect to the same assessee tor the assessment year 1967-68. The judgment of this Court in that case is reported in The Commissioner of Income Tax, Kerala v. Kerala Stale Industrial Development Corporation Ltd. (ILR. 1979(1) Kerala 18). The judgment of this Court in that case is reported in The Commissioner of Income Tax, Kerala v. Kerala Stale Industrial Development Corporation Ltd. (ILR. 1979(1) Kerala 18). Therein this Court held that the order of the Appellate Assistant Commissioner holding that no deduction could be allowed in respect of the amount given by the assessee by way of grant to the Labour and Industrial Bureau would 9onstitute information within the meaning of S.147 on the basis of which the Income Tax Officer could validly initiate the proceedings under S.147(b). In the light of the said decision we have no hesitation to hold that the contrary view taken by the Tribunal is incorrect and unsustainable. We hold in the reopening of the assessment for the assessment year 1968-69 under S.147(b) was valid The question is accordingly answered in the affirmative, that is against the assessee and in favour of the department. There will be no direction regarding costs. A copy of this judgment, under the seal of the Court and the signature of the Registrar, will be forwarded to the Tribunal, as required by law.