Sec. 263 of Income Tax Act, 1961— Revision — Court is not persuaded to come to a conclusion different from the one reached by the ITAT, which purely turned on facts. Indeed the CIT appears to have proceeded on surmises that the investment in shares was out of borrowed funds of the Assessee when plainly it was not., therefore, Court concurs with the view expressed by the ITAT that this issue did not require to be revisited under Section 263 - CIT V/s SAW PIPES LTD. - [2020] 426 ITR 579 (DEL)