The ITAT held that for invoking Explanation 2(a) to section 263 Commissioner cannot only rely about lack of necessary inquiries and verifications but must give an objective finding that Assessing Officer has not conducted, at stage of passing order which is subjected to revision proceedings, inquiries and verifications expected, in ordinary course of performance of duties of a prudent, judicious and responsible public servant that Assessing Officer is expected to be. When investment in shares by assessee-trust had been accepted as part of corpus of trust for over four it was not at all unreasonable on part of Assessing Officer not to question whether or not investments in shares were part of corpus. Provisions under section 263 could not be put into service to make some roving and fishing inquiries. (AY. 2014-2015)