Reopening under section 150(1) fails without a true direction or finding in the earlier order; reassessment was time-barred.

Reopening of completed assessments under section 150(1) was discussed as unavailable where the earlier block assessment order contained only a general observation and not a specific direction or finding requiring reassessment. The Tribunal's prior remark that the disallowance could not bind regular assessment did not authorise reopening of any assessment year, and there was no finding compelling reassessment of foreign travel expenditure. As section 150(1) applies only on a true direction or finding, it could not extend limitation here. Explanation 2 to section 153 was also found inapplicable on the facts, so the reassessments were time-barred and invalid.

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Issues: Whether the reopening of assessments under section 150(1) was barred by limitation because the observations in the earlier block assessment order did not amount to a direction or finding, and whether the reassessment could otherwise be sustained.

Analysis: The earlier order of the Tribunal had only deleted the addition made in block assessment on the ground that the disallowance did not constitute undisclosed income for that proceeding. Its observation that the disallowance could not be treated as an authority against regular assessment was only a general remark and not a specific direction to reopen completed assessments. No finding was given requiring the Assessing Officer to reassess the foreign travel expenditure or to reopen any assessment year. Since section 150(1) operates only where there is a true direction or finding, the reopening could not derive support from that provision. The reference to explanation 2 to section 153 was also held inapplicable on the facts.

Conclusion: The reassessments were time-barred and invalid, and the Revenue's challenge failed.

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