The Tribunal held that the Assessing Officer had made adequate enquiries during the course of assessment proceedings and further in support of its claim, the assessee had submitted all relevant documents and evidence in response to the queries raised by the Assessing Officer. All the issues which were the subject matter of the show-cause notice issued by the Principal Commissioner had already been enquired into by the Assessing Officer, and he, after duly considering the voluminous documents and evidence furnished by the assessee, reached a conclusion after due application of mind. Specific queries were raised by the Assessing Officer, and required details were filed in respect of unsecured loans as well as in respect of refining loss in the gold account. It was not the case of the Department that the assessee did not discharge its onus before the Assessing Officer. Therefore, the view taken by the Principal Commissioner that the Assessing Officer had not conducted necessary enquiries prior to the passing of the assessment order and there was non-application of mind on the part of the Assessing Officer was not tenable. Accordingly, the proceedings under section 263 of the Income-tax Act, 1961, were bad in law and were to be quashed. (AY. 2016-17)