The Assessing Officer reopened the assessment to verify the assessee’s claim of exemption under section 10(38) in respect of long-term capital gains from sale of shares and, after examining the contract notes, bank records and other supporting documents, accepted the claim. The Tribunal held that the assessee had discharged the initial burden by producing all relevant evidence and could not be faulted for the manner in which the Assessing Officer conducted the enquiry. As the Principal Commissioner failed to conduct even a prima facie independent enquiry before invoking section 263, the assessment order could not be regarded as erroneous and prejudicial to the interests of the Revenue. The revision was therefore quashed.  The Principal Commissioner proceeded on the erroneous assumption that the assessee had sold immovable properties, whereas the records established that the transactions were purchases supported by purchase deeds, bank statements, loan records and tax deduction details. The Tribunal held that the Principal Commissioner failed to make even the minimum enquiry before directing a fresh assessment and did not establish that the assessment order was either erroneous or prejudicial to the interests of the Revenue. The revision order under section 263 was therefore held to be invalid  (AY. 2015-16).