The assessment was selected under limited scrutiny for examination of two issues  viz. (1) Low income in comparison to high loan / advances /Investment in shares appearing in balance sheet and (ii) Minimum Alternate Tax (MAT) liability mismatch. The Assessing Officer completed the assessment. PCIT issued show cause notice for revision on the ground that the AO did not verify the capitalisation of interest paid  and passed the revisional order. On appeal the Tribunal held that the AO is not empowered to do certain acts directly, the revisionary authority certainly cannot direct the AO to do so indirectly by exercising power u/s 263 of the Act. Revision order was quashed. Relied on CBDT instruction No. 20/ 2015 dt. 29-12 2015 (2016) 380 ITR 36 (St), CBDT instruction No.  5 of 2016 dt. 14-7-2016 (2016) 385 ITR 56 (St) and also  relied on Su-Raj Diamond Dealers Pvt. Ltd. v. PCIT  (2020) 185 DTR 1 / 203 TTJ 137 (Mum.)(Trib.) (2020) 185 DTR 1 / 203 TTJ 137 (Mum.)(Trib.). (dt. 22-10-2021) (AY. 2015-16)