Allowing the appeal of the revenue the Court held that the operative portion of the show-cause notice under section 263 of the Act showed that the Principal Commissioner had applied his mind and had come to the prima facie conclusion that the Assessing Officer should have treated the entire credit as bogus and added it back rejecting the claim for exemption under section 10(38) of the Act. This was not a case where the Principal Commissioner solely proceeded based on the report of the Assessing Officer but on a perusal of the report had examined the facts. The Tribunal had committed a manifest error in allowing the assessee’s appeal and setting aside the order passed under section 263. The order of revision was valid. Order of Tribunal set aside. (AY. 2014-15)