Dismissing the appeal of the Revenue the Court held that  the notice contemplating initiation of proceeding for revision was issued on March 26, 2021 and the order in revision was passed on March 31, 2021 rejecting request of the assessee for grant of 15 days’ time. Therefore, the Tribunal was correct in holding that the Commissioner passed the order without giving any opportunity to the assessee. A mere statement in the appeal filed by the Department that “no documentary evidence is submitted by the assessee in support of its claim” could not be countenanced in view of the categorical finding of fact by the Assessing Officer as also the Tribunal that the assessee did furnish statements, documents and details as sought for in compliance with the notice issued for assessment under section 143. The revisional authority had mechanically sought to apply the decision of the Tribunal in Grama Vidiyal Trust without application of mind. The order of revision was not valid. The Tribunal was justified in setting aside the order. (AY.2016-17)