The return of income is accepted under section 143(1) of the Act. Commissioner revised the order on the ground that a land was sold by assessee to an entity below value adopted by concerned authority for levy of stamp duty, and therefore, there was under-assessment of income to extent of differential amount, and accordingly, assessment made was contrary to provisions of section 50C of the Act. On appeal the Tribunal held that it was not assessee who effectuated sale of subject land and land was actually sold by secured lenders to recover dues owed to them by assessee. Principal Commissioner had failed to notice these underlying facts while invoking his powers under section 263 of the Act. Accordingly the revision order was quashed. On appeal by the Revenue the court held that the twin conditions for invoking powers under section 263 i.e. not only order should be erroneous, but it should also be prejudicial to interest of revenue were not met. Accordingly the order of the Tribunal is affirmed. SLP of Revenue is dismissed. (AY. 2014-15)