JUDGMENT : Mohammad Rafiq, J. 1. This appeal u/s. 260A of the Income Tax Act, 1961 has been filed challenging the order of the Income Tax Appellate Tribunal Jaipur (for short-'the ITAT') dated 4.4.2018. The ITAT by the aforesaid judgment has allowed the appeal preferred by the respondent-assessee and thereby reversed the order the CIT, Alwar dated 15.3.2016 and restored the assessment order for the assessment year 2011-12 made under Section 143 of the Act on 24.3.2014 by the Assessing Officer. 2. The Assessing Officer by the aforesaid order enhanced the trading income of 2,99,820/- to Rs. 4,55,556/- by making additions out of the various expenses. The CIT, Alwar issued notice u/s. 263 dated 25.01.2016 by invoking its revisional power because in its view, the assessment order was "prejudicial to the interests of Revenue" since the Assessing Officer had not made proper enquiry on various issues. The respondent-assessee contested the notice and filed reply. The CIT however did not upheld the arguments of the assessee and held that the Assessing Officer was required to make proper enquiry to determine whether the money was really lended by the third party or it has come out of the sources of the assessee himself. The apparent source of money is relevant enquiry for ascertaining the genuineness of the loan to which Assessing Officer has failed to apply his mind. Such non-application of mind constituted passing of an erroneous order, which is also prejudicial to the interest of revenue. Regarding the genuineness of the capital introduced in the names of the partners, the reply of the assessee was that all details were furnished, but the CIT concluded that as per the order-sheet entries, no inquiry/verification has been made by the Assessing Officer and there was no application of mind on the part of the Assessing Officer with regard to this aspect. There was no evidence on record that the Assessing Officer had inquired into even the primary details, which were essential for completion of the assessment. The creditworthiness of the alleged lenders was not enquired into and therefore the order was erroneous and prejudicial to the interest of revenue. The Assessing Officer was required to make proper investigation to determine whether the money was really lend by a third party or its has come out of the resources of the assessee himself. The creditworthiness of the alleged lenders was not enquired into and therefore the order was erroneous and prejudicial to the interest of revenue. The Assessing Officer was required to make proper investigation to determine whether the money was really lend by a third party or its has come out of the resources of the assessee himself. The absence of proper enquiry would render the assessment order as erroneous as well as prejudicial to the interest of revenue. The ITAT has however not concurred with the view taken by the CIT and held in para 7 as under: "7. The Bench have heard both the sides on the issue, perused the material available on the record and also perused the case laws relied upon. Assessment year 2011-12 was the first year of operation of the assessee company. It was a partnership firm having 17 partners and the share of the each partner was specified as evidence from page No. 28 of the paper book. The assessee firm commenced the business of contractor ship in the name and style of Hari Om Stones with Mining Department and Sales tax department to collect to revenue for government. The partnership deed is placed at page Nos. 26 to 31 of the paper book. This partnership deed also specifies in para 10 that the partners to whom the remunerations is to be paid and limit of the same is also specified. This document was submitted to the Assessing Officer during assessment proceedings. This case was selected for compulsory and complete scrutiny. The assessment for assessment year 2011-12 was made U/s 143(3) of the Act on 24/3/2014. The returned income of Rs. 2,99,820/- was enhanced to Rs. 4,55,556/- and the additions were made out of various expenses. The Assessing Officer made enquiries on various issues and the assessee submitted such details asked for. The enquiry with regard to remuneration to the partners and expenses/receipts were also conducted by the Assessing Officer. Such facts are evident from page Nos. 105 to 106 of the paper book which is a letter dated 11/3/2014 submitted before the Assessing Officer. Another letter placed at page Nos. 50 to 52 of the paper book was also establishes that the books of accounts were produced before the Assessing Officer. Such facts are evident from page Nos. 105 to 106 of the paper book which is a letter dated 11/3/2014 submitted before the Assessing Officer. Another letter placed at page Nos. 50 to 52 of the paper book was also establishes that the books of accounts were produced before the Assessing Officer. Thus, these facts suggest that the Assessing Officer has taken into consideration the material before him and after due application of law and of facts and then reached at the conclusion to conclude the assessment U/s 143(3) of the Act. It was not a case where Assessing Officer completed the assessment without conducting necessary and proper enquiries. The issue raised by the ld. Pr. CIT has been considered by the assessing Officer at the time of assessment and the assessee has submitted evidences and details in support of its claim made in P&L account. Therefore, in our considered view, the order passed by the Assessing Officer U/s 143(3) of the Act on 24/3/2014 was not an erroneous order, which could be said to be prejudicial to the interest of the revenue. Considering the ratio laid down in various case laws relied upon, we set aside the order passed by the ld. Pr. CIT." 3. We are inclined to concur with the view expressed by the ITAT as the order of assessment indicate that the Assessing Officer has made enquiry on various issues and assessee submitted the details therefore. The enquiry pertained to the remuneration of the partners and the expenses/receipts. The Assessing Officer enhanced the return income of the assessee of Rs. 2,99,820/- to Rs. 4,55,556/- by making additions out of the various expenses. The nature of the assessment order does not bring the case of the revenue within the purview of Section 263 of the Income Tax Act as such order cannot be said to be "prejudicial to the interests of Revenue." 4. We may in this connection refer to the judgement of the Supreme Court in Malabar Industrial Co. Ltd. vs. Commissioner of Income Tax, Kerala State- (2000) 2 SCC 718 . The Supreme Court in that case while not approving of the view taken by the Madras High Court in Venkatakrishna Rice Co. We may in this connection refer to the judgement of the Supreme Court in Malabar Industrial Co. Ltd. vs. Commissioner of Income Tax, Kerala State- (2000) 2 SCC 718 . The Supreme Court in that case while not approving of the view taken by the Madras High Court in Venkatakrishna Rice Co. vs. CIT-, (1987) 163 ITR 129 (Mad.) on the phrase "prejudicial to the interests of the Revenue" held that the scheme of the Act is to levy and collect tax in accordance with the provisions of the Act and this task is entrusted to the Revenue. If due to an erroneous order of the Income Tax Officer, the Revenue is losing tax lawfully payable by a person, it will certainly be prejudicial to the interests of the Revenue. The phrase "prejudicial to the interests of the Revenue" is not an expression of art and is not defined in the Act. When this phrase is understood in its ordinary meaning, it is of wide import and is not confined to mere loss of tax. Relevant discussion is found in Paras 8, 9 and 10 of the Report, which are reproduced as follows: "8. The phrase "prejudicial to the interests of the Revenue" is not an expression of art and is not defined in the Act. Understood in its ordinary meaning it is of wide import and is not confined to loss of tax. The High Court of Calcutta in Dawjee Dadabhoy & Co. v. S.P. Jain (1957) 31 ITR 872 (Cal), the High Court of Karnataka in CIT v. T. Narayana Pai (1975) 98 ITR 422 (Kant), the High Court of Bombay in CIT v. Gabriel India Ltd. (1993) 203 ITR 108 (Bom), and the High Court of Gujarat in CIT v. Minalben S. Parikh (1995) 215 ITR 81 (Guj) treated loss of tax as prejudicial to the interests of the Revenue. 9. Mr. Abraham relied on the judgment of the Division Bench of the High Court of Madras in Venkatakrishna Rice Co. v. CIT (1987) 163 ITR 129 (Mad) interpreting "prejudicial to the interests of the Revenue". The High Court held: "In this context, (it must) be regarded as involving a conception of acts or orders which are subversive of the administration of revenue. v. CIT (1987) 163 ITR 129 (Mad) interpreting "prejudicial to the interests of the Revenue". The High Court held: "In this context, (it must) be regarded as involving a conception of acts or orders which are subversive of the administration of revenue. There must be some grievous error in the order passed by the Income Tax Officer, which might set a bad trend or pattern for similar assessments, which on a broad reckoning, the Commissioner might think to be prejudicial to the interests of Revenue Administration". In our view this interpretation is too narrow to merit acceptance. The scheme of the Act is to levy and collect tax in accordance with the provisions of the Act and this task is entrusted to the Revenue. If due to an erroneous order of the Income Tax Officer, the Revenue is losing tax lawfully payable by a person, it will certainly be prejudicial to the interests of the Revenue. 10. The phrase "prejudicial to the interests of the Revenue" has to be read in conjunction with an erroneous order passed by the Assessing Officer. Every loss of revenue as a consequence of an order of the Assessing Officer cannot be treated as prejudicial to the interests of the Revenue, for example, when an Income Tax Officer adopted one of the courses permissible in law and it has resulted in loss of revenue; or where two views are possible and the Income Tax Officer has taken one view with which the Commissioner does not agree, it cannot be treated as an erroneous order prejudicial to the interests of the Revenue unless the view taken by the Income Tax Officer is unsustainable in law. It has been held by this Court that where a sum not earned by a person is assessed as income in his hands on his so offering, the order passed by the Assessing Officer accepting the same as such will be erroneous and prejudicial to the interests of the Revenue. (See Rampyari Devi Saraogi v. CIT (1968) 67 ITR 84 (SC) and in Tara Devi Aggarwal v. CIT (1973) 3 SCC 482 )". 5. In view of above discussion, we do not find any infirmity in the order passed by the ITAT and therefore the present appeal does not raise any question of law much less substantial question of law. 6. The appeal is therefore dismissed.