From what I can understand, counting-to-infinity occurs when one router feeds another old information, which continues to propagate through the network toward infinity. From what I read, this can definitely occur when a link is removed.
So in this example, the Bellman-Ford algorithm will converge for each router, they will have entries for each other. R2 will know that it can get to R3 at a cost of 1, and R1 will know that it can get to R3 via R2 at a cost of 2.
If the link between R2 and R3 is disconnected, then R2 will know that it can no longer get to R3 via that link and will remove it from it's table. Before it can send any updates it's possible that it will receive an update from R1 which will be advertising that it can get to R3 at a cost of 2. R2 can get to R1 at a cost of 1, so it will update a route to R3 via R1 at a cost of 3. R1 will then receive updates from R2 later and update its cost to 4. They will then go on feeding each other bad information toward infinity.
One thing I have seen mentioned a few places is that there can be other causes of counting to infinity other than just a link going offline such as changing the cost of a link. I got to thinking about this and from what I can tell, it seems to me that perhaps the cost of a link being increased could cause the problem. However, I do not see that it's possible for a lowering cost to cause the problem.
For instance, in the example above, when the algorithm converges and R2 has a route to R3 at a cost of 1, and R1 has a route to R3 via R2 at a cost of 2. If the cost between R2 and R3 is increased to 5. Then this would cause the same problem, R2 could get an update from R1 advertising a cost of 2, and change its cost to 3 via R1, R1 then changing its route via R2 to a cost of 4 and so on. However, if the cost decreases on a converged route then it wouldn't cause a change. Is this correct? It is an increasing cost between links that may cause the problem, not decreasing cost? Are there any other possible causes? Would taking a router offline be the same as a link going out?