The AO completed assessment under section 143(3) accepting total loss declared in return of income. PCIT held that during the year under consideration, the assessee had made export sales to its US based related entity. On verification, it was found that the assessee had not filed Form 3CEB report electronically in respect of the international transactions entered into by it. Therefore, held that the assessment order passed by the AO is erroneous inasmuch as it is prejudicial in the interest of the revenue by reason of failure by the AO to  make proper inquiry/verification regarding the levy of penalty under S 271BA and also reference to TPO under section 92C. It was contended that it had filed Form 3CEB report manually, therefore, it could not be said that assessee had not furnished a report as required under S. 92E of the Act . Tribunal held that  issue was not examined by the AO as the assessee has also not brought on record that why the aforesaid report in 3CEB was not filed electronically. To this extent, PCIT was justified in invoking the provision of S. 263 holding that the order passed by the AO as erroneous and prejudicial to the interest of revenue to the extent of non-filing of Form 3CEB report. The assessee may submit corresponding reasons for not filing the Form 3CEB electronically before the CIT(A) at the time of appellate proceedings. In the light of the above facts and circumstances, no anomalies were to be found in the decision of the Commissioner  for revision to the extent of default in filing Form 3CEB report in electronic mode as prescribed. Tribunal also held that as regards freight charges paid by the assessee to shipping agent of non-resident shipping companies is attracted S.172 and not 194C or 195 hence PCIT is not justified in exercising revision for non  deduction of tax at source . ( AY. 2013-14)