Assessee, a non-profit company, filed nil return and claimed exemption under Section 11. Assessing Officer examined the materials submitted by the assessee and completed the assessment under section 143(3), assessing income at Nil. Commissioner (E) initiated revision proceedings on the ground that Assessing Officer had neither called for breakup details nor examined supporting documents substantiating utilisation of Rs. 6 crores accumulated under section 11(2). He, thus, invoked Explanation 2 to section 263 and set aside the assessment order with directions to obtain complete details and evidence, examine alignment with the assessee’s objects/MOA, and conduct third-party verification. Tribunal set aside the order of the CIT(E). On appeal the Court held that the assessee had furnished board resolutions, Form No. 10, and details of utilisation of funds, along with details of accumulation of funds made under section 11(2) and on the basis of verification of said documents, the Assessing Officer had passed the assessment order. Since the Assessing Officer had conducted enquiries and applied his mind, and had taken a possible view of the matter, then Commissioner (E), on the basis of another possible view, could not pass orders under section 263, merely because he had a different opinion in the matter. Court also held that since the Commissioner (E) invoked Explanation 2 in the revision order without confronting the assessee in a show-cause notice, the assumption and exercise of revisional jurisdiction were not sustainable. Court also held that the Commissioner (E) had not recorded any finding of non-utilisation by end of the permitted accumulation period. Court observed that, with regard to section 11(2) read with section 11(3), any alleged misapplication or non-examination of utilization of accumulated income for assessment year 2016-17 could be brought to tax or examined only in the year immediately following expiry of the accumulation period, i.e., assessment year 2022-23. Accordingly, the revision order was quashed. (AY. 2017-18)