JUDGMENT : R.S. JHA, J. This appeal has been filed by the Assessee under the provisions of section 260-A of the Income Tax Act, 1961 against the order passed by the Income Tax Appellate Tribunal in I.T.A. No. 78/Jab/2015 dated 18-1-2017 for the assessment year 2010-11. 2. The learned Senior Counsel appearing for the appellant submits that the appellant had filed a return in respect of the aforesaid assessment year before the Assessing Authority and the Assessing Authority by order dated 30-3-2013 assessed the appellant to tax. It is stated that the Commissioner of Income Tax, Jabalpur issued a notice under section 263 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) to the appellant proposing to invoke the powers of suo motu revision in respect of the order of assessment dated 30-3-2013 on the ground that it was erroneous and prejudicial to the interest of revenue. It is stated that the appellant had filed a detailed reply to the same, however, the Commissioner of Income Tax, without considering the documents on record or the reply of the appellant, passed an order on 27-3-2015 invoking the powers under section 263 of the Act and remitting the matter back to the Assessing Officer for conducting a proper assessment. 3. The appellant being aggrieved filed an appeal against the order dated 27-3-2015 before the Income Tax Appellate Tribunal, Jabalpur Bench, which has been dismissed by the impugned order dated 18-1-2017. Hence the appellant has filed this appeal on the following substantial questions of law. “(i) Whether the Tribunal is correct in law in upholding the order of the Commissioner of Income Tax-1, Jabalpur without any sound basis and that the finding of the Tribunal is perverse? (ii) Whether the Tribunal was correct in law in upholding that the order passed by the CIT-1, Jabalpur which has been passed without considering the documents on record and without providing reason as to how the order passed by the Assessing Officer is erroneous and prejudicial to the interest of the Revenue?” 4. (ii) Whether the Tribunal was correct in law in upholding that the order passed by the CIT-1, Jabalpur which has been passed without considering the documents on record and without providing reason as to how the order passed by the Assessing Officer is erroneous and prejudicial to the interest of the Revenue?” 4. The learned Senior Counsel appearing for the appellant, taking us through the substantial questions of law framed by him as aforesaid, submits that the power exercised by the authority under section 263 of the Act, is unsustainable in view of the fact that there is no finding recorded by the Tribunal to the effect that the order is prejudicial to the interest of revenue. The learned Senior Counsel appearing for the appellants submits that it is settled law that merely because an order of assessment is erroneous, it does not mean that it is also prejudicial to the interest of revenue and, therefore, the power under section 263 of the Act, can be imposed only in case where the authority concerned records a specific finding to the effect that the impugned order is erroneous and is also prejudicial to the interest of revenue. It is submitted that in the absence of recording a finding in respect of both the aforesaid issues, the powers under section 263 of the Act, cannot be invoked and therefore, the impugned orders be set aside. 5. Having heard the learned senior counsel appearing for the appellant, we find that the substantial questions of law framed in this appeal only relate to the correctness of the view taken by the Commissioner of Income Tax in the proceedings under section 263 of the Act, and as to whether the finding recorded by him has been arrived at without considering the documents on record and without recording any reason for arriving at the conclusion that the order passed by the Assessing Officer is erroneous and prejudicial to the interest of revenue. 6. However, in view of the extensive arguments extended by the learned Senior Counsel appearing for the appellant, we proceed to examine as to whether there is a finding recorded by the authority concerned in respect of the issue that the order passed by the Assessing Officer in the present case is erroneous as well as prejudicial to the interest of revenue. 7. 7. From a perusal of the impugned order passed by the Income Tax Appellate Tribunal, specifically paragraphs 4 to 4.8, it is apparent that the Income Tax Appellate Tribunal has examined the record and has arrived at a finding that the present case is one where the Assessing Officer has not conducted any enquiry or applied his mind to the voluminous return and documents filed by the appellant while passing the order of assessment. 8. The Income Tax Appellate Tribunal, by relying on the decision of the Supreme Court rendered in the case of Malabar Industrial Co. Ltd. v. CIT, (2000) 243 ITR 83 (SC), the order passed by the Supreme Court in the case of Rampyari Devi Saraogi v. Commissioner of Income Tax, (1968) 67 ITR 84 (SC) and Commissioner of Income Tax, Mumbai v. Amitabh Bachchan, (2016) 11 SCC 748 : AIR 2016 SC 2257 relevant extracts of which have been quoted by the Income Tax Appellate Tribunal in paragraphs 4.2 and 4.3 of its order, has arrived at a conclusion that as the Assessing Officer has passed the order of assessment without making a proper enquiry and without applying his mind to the return and the documents filed by the assessee, as such the order is erroneous as well as prejudicial to the interest of revenue. The Tribunal has also recorded a finding of fact, on the basis of the record available, that in the instant case, though the Assessee has submitted records before the Assessing Officer, he has simply accepted the claim of the assessee without examining the same and therefore, the present case is one where the impugned order of assessment is erroneous as well as prejudicial to the interest of revenue on account of lack of enquiry and application of mind to the facts of the case by the Assessing Officer. 9. The learned Senior Counsel appearing for the appellant has vehemently submitted that as the assessee had produced the records before the Assessing Officer and had placed all material before him, he cannot be punished for lack of application of mind or enquiry by the Assessing Officer. Be that as it may, in the present case this Court is only required to examine the correctness of the exercise of power under section 263 of the Act. Be that as it may, in the present case this Court is only required to examine the correctness of the exercise of power under section 263 of the Act. On a careful perusal of the record, it is apparent that the Commissioner of Income Tax as well as the Income Tax Appellate Tribunal both have recorded a finding to the effect that though the records were filed before the Assessing Officer and a detailed questionnaire was also issued to the appellant by the Assessing Officer to which a reply was filed by the appellant in that regard, the Assessing Officer did not apply his mind nor did he conduct an enquiry into the matter although he has recorded in the note-sheet that the reply filed by the appellant was not satisfactory and did not explain all the facts. 10. The Income Tax Appellate Tribunal on the basis of this finding of fact recorded by it has held that the present case is one of total lack of enquiry and by placing reliance on the decisions rendered by the Supreme Court in the cases of Malabar Industrial Co. Ltd. (supra) and Ram Pyari Devi Saraogi (supra) as well as the decision of Special Bench of the Income Tax Appellate Tribunal, has recorded a conclusion that such an order is erroneous and prejudicial to the interest of revenue in view of the law laid down by the Supreme Court. 11. The Supreme Court in the case of Malabar Industrial (supra) extensively interpreting and explaining the powers of revision conferred under section 263 of the Act upheld the order invoking the powers of revision on the ground that the Income Tax Officer passed an order of assessment without application of mind and by blindly accepting the entry in the statement of the account filed by the appellant without making any inquiry in the following terms:— “(11) In the instant case, the Commissioner noted that the Income-tax Officer passed the order of nil assessment without application of mind. Indeed, the High Court recorded the finding that the Income-tax Officer failed to apply his mind to the case in all perspective and the order passed by him was erroneous. It appears that the resolution passed by the board of the appellant-company was not placed before the Assessing Officer. Indeed, the High Court recorded the finding that the Income-tax Officer failed to apply his mind to the case in all perspective and the order passed by him was erroneous. It appears that the resolution passed by the board of the appellant-company was not placed before the Assessing Officer. Thus, there was no material to support the claim of the appellant that the said amount represented compensation for loss of agricultural income. He accepted the entry in the statement of the account filed by the appellant in the absence of any supporting material and without making any inquiry. On these facts the conclusion that the order of the Income-tax Officer was erroneous is irresistible. We are, therefore, of the opinion that the High Court has rightly held that the exercise of the jurisdiction by the Commissioner under section 263(1) was justified.” The same view in similar circumstances, has again been taken by the Supreme Court in the case of Commissioner of Income Tax, Mumbai v. Amitabh Bachchan, (2016) 11 SCC 748 : AIR 2016 SC 2257 by placing reliance on its previous decision rendered in the case of Malabar Industrial (supra). 12. In the facts and circumstances of the present case, we do not find any substantial question of law arising for adjudication in the present appeal, in view of the peculiar facts prevailing in the present case, namely, total lack of enquiry by the Assessing Officer leading to rendering the impugned order erroneous and prejudicial to the interest of revenue, in the light of decisions of the Supreme Court in the cases of Malabar Industrial Co. Ltd. (supra), Ram Pyari Devi Saraogi (supra) and Amitabh Bachchan (supra) and, therefore, the appeal filed by the appellant being merit-less is accordingly dismissed.