On appeal the Tribunal held that it was not a case where no enquiry was made by the Assessing Officer during the course of assessment proceedings or that the Assessing Officer failed to apply his mind to the issues on hand and taken a view which was not legally plausible on the facts and set aside the revision order under section 263 on the ground that merely because the Principal Commissioner had a different opinion he should not have invoked revision jurisdiction. On appeal was not legally plausible on the facts and set aside the revision order under section 263 on the ground that merely because the Principal Commissioner had a different opinion he should not have invoked revision jurisdiction. On appeal Tribunal held that   the assessee did not create any mortgage on the property but he had given a personal guarantee to the entity  for discharge of the debt for which there was a charge over the property and for release of the mortgage on the personal guarantee of the assessee, the amount was paid by the buyer directly to the entity Titco Ltd. It was also not in dispute that the assessee did not avail of any loan on mortgage of the property sold by him. The Tribunal  had rightly held that the assessment order by the Assessing Officer was neither erroneous nor prejudicial to the interests of the Revenue. No substantial question of law. (AY. 2013-14)