Judgment :- A. SUBBULAKSHMY, J. 1. We do not find any merit in this petition. 2. The audit report has been the basis for the reopening of the assessment and it has rightly been so held by the Tribunal. The audit report did not merely draw the attention of the officer to the legal provision, but dealt with the facts of the case at great length, and incidentally mentioned the provision of law. 3. We do not find any necessity to call for a reference. The tax case petition is dismissed.