Held that the assessee has  submitted all the details relating to the capital raised by the company, expenses incurred in relation to consultancy, and the fees paid to the Registrar of Companies for increasing the capital base of the company along with documentary evidence, and the AO having taken a conscious decision to allow deduction of consultancy fees, after considering all the aspects in the assessment proceedings.  The order of the AO is neither erroneous nor prejudicial to the interest of the Revenue and therefore, the order passed by the Principal CIT under s. 263 cannot be sustained. (AY. 2018-19)