Dismissing the appeal the Court held that, the Tribunal had clearly recorded that this was not a case where the Assessing Officer had not made any inquiry and blindly accepted the return filed by the assessee. The Assessing Officer had called for particulars at the time of the scrutiny assessment proceedings, received the reply and following the principles of natural justice, passed an assessment order expressing his opinion in the matter. The Commissioner could not substitute his opinion on the view taken by the Assessing Officer to say that the assessment order was erroneous and prejudicial to the interests of the Revenue. Where two views are possible and the ITO has taken one view with which the Commissioner does not agree, it cannot be treated as an order erroneous and prejudicial to the interests of the Revenue unless the view taken by the Assessing Officer is unsustainable in law. Order of Tribunal is affirmed. (AY.2006-07)