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3. Brief facts of the case are that the assesseM/s. Mahasemam Trust registered u/s.12A(a) of the Income Tax Act, 1961 and also u/s.18G of the Act, is engaged in providing micro financing activity filed its return of income for assessment year 2016-17 declaring total income as Nil after availing exemption u/s.11 of the Income Tax Act, 1961. The assessment for impugned assessment year has been completed u/s.143(3) of the Act, on 31.12.2018 and accepted returned income after allowing benefit of exemption u/s.11 of the Act. The case has been subsequently taken up for revision proceedings u/s.263 of the Act, and hence show cause notice dated 20.06.2019 was issued u/s.263 of the Act and called upon the assessee to explain as to why assessment order passed by Assessing Officer u/s.143(3) dated 31.12.2018 shall not be revised for reasons stated in the show cause notice. The learned PCIT in the show cause notice has alleged that assessment order passed by the Assessing Officer is erroneous, insofar as it is pre-judicial to the interests of revenue, because the Assessing Officer has allowed benefit of section 11 & 12 of the Act to the trust, without appreciating fact that activity carried out by the assessee i.e micro financing is hit by proviso to section 2(15) of the Income Tax Act, 1961 and hence, entire income should be taxed as an AOP. In response to show-cause notice, the assessee vide its letter submitted that assessment order passed by the Assessing Officer is neither erroneous nor pre-judicial to the interests of revenue, because the Assessing Officer has completed assessment, after having considered various materials placed by the assessee during the assessment proceedings, including decision of ITAT, Chennai in assessee's own case for earlier years, where the Tribunal has held that activity carried out by the assessee is charitable in nature, which is not hit by proviso to section 2(15) of the Act. Since the Assessing Officer has examined issue and taken one of the possible view on the issue and allowed benefit of exemption to the assessee u/s.11 & 12 of the Act, the PCIT cannot say that assessment order passed by the Assessing Officer is erroneous, insofar as it is pre- judicial to the interests of revenue.