Tribunal held that there were two divergent opinions of two High Courts on the issue, the Delhi High Court holding that the notional annual value of unsold flats should be assessed as income from house property, and the Gujarat High Court that income derived from property held as inventory was taxable as business income. The Assessing Officer had taken one possible view. Where two views are possible and the Assessing Officer takes one possible view with which the Commissioner does not agree, this would not make the assessment order erroneous. Section 263 of the Act requires two conditions to be satisfied: not only should the order of the Assessing Officer be erroneous, it should also be prejudicial to the interests of the Revenue. in the instant case, the assessment order did not suffer from any error, and the order of the Principal Commissioner was liable to be quashed as he was clearly in error in invoking revisional jurisdiction under section 263 of the Act.  Relied on Malabar industrial co. ltd. v. CIT (2000) 243 ITR 83 (SC) and CIT v. Max India Ltd. (2007 ) 295 ITR 282 (SC). Tribunal also held that  section 23(5) , whereby notional annual value of property held as stock-in-trade was brought to tax subject to conditions thereunder, was applicable only from April 1, 2018 and not for the assessment year under consideration here. Thus, no addition on account of notional rental value of the flats held as stock in trade by the assessee could have been made by the Assessing Officer in the assessment years in question. (AY. 2014-15, 2015-16)