Allowing the petition, that suo motu revisional proceeding for the assessment year 2017-18 were initiated merely on the basis of a proposal under section 263 without independent application of mind by the Principal Commissioner on the basis of a proposal submitted by the Assistant Commissioner and forwarded by the Joint Commissioner. Hence, the very initiation of the proceeding was illegal, without jurisdiction and untenable. The long-term capital gains in question were exempt and therefore, the non-disclosure of the amount could not result in prejudice to the Department. The net long-term capital gains was shown in the return after deduction of the long-term capital loss and both the long-term capital gains and long-term capital loss were duly shown in the return. Even if the amount in question was considered long-term capital gains there would have been no further tax liability and non-disclosure of such amount could not be prejudicial to the interests of the Revenue since there was no loss of revenue. Therefore, one of the preconditions for the exercise of powers under section 263 had not been fulfilled. Hence, the notice for initiation of proceedings and the subsequent ex parte order passed under section 263 were quashed and set aside.  (AY.2017-18)