Section 263: Assessment Orders Not Erroneous Just for Lacking Reasons, Must Show AO's Failure in Law or Facts.

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....Revision u/s 263 - loss on sale of shares - non-mentioning of the reasons for allowing the claim, will not make the assessment order erroneous. To hold the assessment order to be erroneous it has to be stablished that the AO had not applied his mind to the facts of the case or that he has not applied the correct law or has not appreciated the facts correctly. Thus, the assessment order cannot be held to be prejudicial to the interests of the revenue on this issue. - AT....