The Assessing Officer after scrutiny passed the order of assessment accepting the assessee’s declaration of rental income as well as computation of income from other sources. The Commissioner issued a notice of revision on the grounds that the rental income was too low and there had been excess deduction of expenses. On a writ petition to quash the notice. Court held that, the opinion that the rental income was low was based on comparison. The comparison was wholly erroneous. Firstly, the Commissioner merely proceeded to record that both the immovable properties, namely, the mall managed by the assessee-company and one managed by G, were situated in the nearby locality, without giving the distance between the two properties and without even prima facie ascertaining their respective locations. The Commissioner also merely adopted the respective municipal taxes of the two properties as the basis for considering commercial rental value of these properties. Regarding the expenditure the Assessing Officer had carried out detailed inquiry during the course of assessment proceedings. Merely because the Commissioner held a different belief that would not permit him to take the order in revision. Clearly a case of full inquiry had been made by the Assessing Officer before he made up his mind. This was not a case where there were no inquiries or no germane inquiries having been made. The notice of revision was not valid. (AY. 2013-14)