Held that the assessee explained the issues in response to the notices of the Principal Commissioner. The formation of the opinion and belief of the Principal Commissioner changed from time to time after receiving the reply of the assessee. The Principal Commissioner in his third show-cause notice sought to consider the taxability of deemed rental income not under section 23(5) but under section 23(1)(a) of the Act. The Principal Commissioner had not shown with cogent evidence how the submission made by the assessee was incorrect. All facts and submissions with regard to offer of rental income were on record before the Principal Commissioner. The order of the Assessing Officer was neither erroneous nor prejudicial to the interests of the Revenue and the action under section 263 of the Act was beyond jurisdiction. Amendment bringing notional annual value of  property held as stock-in-trade to tax is  prospective.  Revision is not valid.   (AY. 2017-18)