The Hon’ble Gujarat High Court decided an appeal on the substantial questions of law involving issues relating to S. 263 of the Act. In such circumstances it was observed that since there was nothing on record to point out that documents pertaining to survey could have led to a belief different from one entertained by Assessing Officer, Tribunal was justified in holding that non-examination of records could not be basis for invoking revisional jurisdiction under S. 263 and PCIT could not have assumed the jurisdiction on mere change of opinion on his part, when the Assessing Officer while during the course of regular assessment has made inquiry regarding the issue which is the subject matter of the revision.(AY. 2017-18)