The PCIT had invoked his jurisdiction u/s 263 of the Act despite admitting that based on evidence available on record, the AO could not doubt the purchase and sale of shares. After completion of assessment, some investigation was carried out by the department, which allegedly revealed that the share transaction was through an entry operator, hence, non-genuine. However, what was the nature of such investigation, what was the material brought on record therefrom was not forthcoming either from the SCN or the order passed u/s 263 or to what extent the Assessee or the concerned broker was involved in such non-genuine transactions has not been discussed by the PCIT. Further, in spite of repeated requests, such adverse materials/ investigation report was never confronted to the Assessee. In such circumstances, the assessment order cannot be considered to be erroneous and prejudicial to the interest of revenue. (AY. 2017-18)