The assessee, a wholly-owned Government company under voluntary liquidation since 2012, declared nil taxable income after setting off its total income against brought-forward business losses, without AO examining the applicability of MAT under section 115JB, leading the PCIT to invoke revision under section 263 on the ground that the assessment order was erroneous and prejudicial to the Revenue. On appeal, the Tribunal held that since the twin conditions under section 263 require an erroneous order prejudicial to the interests of the Revenue, and the Assessing Officer had neither enquired into nor applied the provisions of section 115JB, there was an incorrect assumption of facts coupled with incorrect application of law, and it was not a case of mere change of opinion; it further held that section 115JB contains no exemption for companies under voluntary liquidation, that the mechanism for accounts prescribed under the Companies Act does not override the Act, that the recognition of liquidation entities in the ITR-6 pro forma exempting them from filing balance-sheet and profit and loss schedules could not be read as a blanket exemption from MAT, and that profits and losses were determinable under any system of accounts followed by the assessee, enabling computation under section 115JB; since the assessee’s case did not fall within any statutory exception, the provisions of section 115JB were clearly applicable, and the revision order was upheld. (AY. 2018-19)