The Tribunal held that the issue which has been racked up by Ld. Pr. CIT in the  revision order was never the subject matter of examination either by Ld. TPO or by Ld. AO during the course of regular assessment proceedings. The queries raised by lower authorities during the course of regular assessment proceedings and the assessee’s replies thereto do not address the issue as highlighted by Ld. Pr. CIT in the  order. The Ld. Pr. CIT has flagged a pertinent issue and fully justified as to how the assessment order was erroneous as well as prejudicial to the interest of the revenue. Upon perusal of assessment orders, the Tribunal found   that this issue was never delved into by Ld. AO or Ld. TPO and there was complete non-application of mind on the sated issue. Accordingly the observation made by Ld. Pr. CIT in the  order could not be faulted with. The revision jurisdiction is perfectly valid and justified.  (AY. 2013-14)