Once the claim of creation of Goodwill as a result of merger and the depreciation charged thereon in the first year, i.e. F.Y. 2016-17 has been accepted by the AO, then during the subsequent year, there is opening balance of written down value. Once that is so, and the claim for depreciation in the subsequent year is supported by the audited balance sheet and tax audit report the AO had no reason to suspect the depreciation claimed on the opening written down value. Hence, the PCIT could not exercise jurisdiction under section 263 to term the said claim of depreciation as erroneous on the ground that the AO did not verify the said claim during assessment proceedings.