Petitioners purchased an immovable property (land) in Goa and showed same under head Investment. In year 2014, they converted said property into stock-in-trade for purpose of development.  In assessment year 2015-16, they computed profits from sale of said property after giving effect to provisions of section 5A.Thereafter, they filed petition under  section 264 and applied for revision of intimation under section 143(1) for assessing gain on sale of said property as business income.  However, Commissioner had rejected said application on the ground that since petitioners had not produced any evidence to support their claim of conversion of said capital asset into stock-in-trade and neither books of account/ledgers nor balance sheets were produced by petitioners along with their application under section 264 of the Act. On writ allowing the petition interests of justice would require that petitioners should be given an opportunity to produce relevant material before Commissioner, and thus, matter be remanded back.