Dismissing the appeal, the Court held that the Tribunal had examined the entire record and found that the Assessing Officer had raised several queries and had also demanded documents through the questionnaire which was comprehensive and covered all relevant aspects of the share issue transactions. The assessee had answered and furnished all the requested documents to the Assessing Officer, and had also informed the Principal Commissioner who had taken proceedings under section 263. The Principal Commissioner had not pointed out any further enquires which were required to be made by the Assessing Officer. The power under section 263 could not be invoked in such circumstances by the Principal Commissioner. The factual aspects had been completely and thoroughly examined by the Tribunal. The order passed by the Principal Commissioner was not sustainable and had been correctly quashed by the Tribunal.(AY. 2018-19)