Held that, the Assessing Officer had duly made enquiries from the assessee as to the nature and the source of the surrendered income and called upon him to show cause why it should not be charged at a higher rate of tax according to the provisions of section 115BBE of the Act. The Assessing Officer after considering the submissions and explanations of the assessee had accepted the contention of the assessee that the surrendered income was out of the business income of the assessee. The Principal Commissioner had not pointed out why the explanation offered by the assessee to the Assessing Officer was not satisfactory and what further enquiries were required to be conducted, which the Assessing Officer had failed to conduct. The Principal Commissioner based his opinion and order on the audit objections and report. Therefore, there was no justification on the part of the Principal Commissioner in invoking the revisionary jurisdiction. (AY. 2017-18)