Held that the assessee had furnished the relevant details and explained the issues raised through the show-cause notice by the Principal Commissioner, supporting its contentions by corroborative documentary evidence. The Principal Commissioner had not applied his mind to arrive at a conclusion that the order was erroneous in so far as prejudicial to the interests of the Revenue, for passing the order under section 263 of the Act. The issue was purely on the facts which were verifiable from the records of the assessee. Examination and verification of the audited financial statements revealed the correct state of its affairs in respect of the issue raised in the revision proceedings which the Department had not controverted. Revision was quashed. (AY.2011-12)