Tribunal held that the AO has raised specific queries which were submitted by the assessee, after verification the assessment order was passed. While passing the  order the Principal CIT has not indicated the failure on the part of the AO that he did not specifically deal with Annex. 3 and annex. 23. Principal CIT invoked the provision of s. 263 only for the reasons that the AO has not raised any question and assessee has not filed any reply. The Tribunal held that the conduct itself suggests that the action of the Principal CIT is based on surmises and conjectures.  The Tribunal also held that nowhere in the order the Principal CIT invoked the Expln. 2 of s. 263 which implies that she was not sure as to whether the order fell within any of the criteria given vide Expln. 2. Order passed by the Principal CIT is quashed.(AY. 2017-18)