If CIT wanted to take a different view, then he should have made a detailed enquiry at revision stage and should have come to the finding as to how the assessment order was erroneous and prejudicial to the interests of Revenue. The Ld. CIT(E) merely mentioned that since these issues have not been enquired into by the A.O, therefore, Explanation-2 to Section 263 of Income Tax Act, 1961, would apply against the assessee. Further, assessee has explained all the issues at original assessment stage as well as before Ld. CIT(E) in proceeding under section 263 of the Income Tax Act, 1961. Therefore, it is not fitcaseof invocation of jurisdiction under section 263 of the Income Tax Act, 1961 against the assessee. Considering the totality of the facts and circumstances of thecase, we are of the view that Order under section 263 of Income Tax Act, 1961 is wholly unjustified and is liable to be set aside.