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An assessment can be revised under section 263 where the Assessing Officer makes no specific enquiry or proper verification of a deduction claim or business loss claim. Mere calling for general details, without follow-up examination, does not show application of mind. On the record described, no discernible opinion had been formed on the section 54B claim or the petrol and diesel evaporation loss, so the matter was not one of change of opinion. Applying Explanation 2(a), such an assessment is treated as erroneous and prejudicial to the Revenue, and the revisional order was sustained.
An assessment can be revised under section 263 where the Assessing Officer makes no specific enquiry or proper verification of a deduction claim or business loss claim. Mere calling for general details, without follow-up examination, does not show application of mind. On the record described, no discernible opinion had been formed on the section 54B claim or the petrol and diesel evaporation loss, so the matter was not one of change of opinion. Applying Explanation 2(a), such an assessment is treated as erroneous and prejudicial to the Revenue, and the revisional order was sustained.
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