https://www.taxtmi.com/caselaws?id=796577 Depreciation on BOT toll-road development cost was not allowable merely by treating toll-collection rights as an intangible asset. The notes state that, where road ownership does not vest in the assessee, CBDT Circular No. 9/2014 requires the development cost to be amortised over the concession period. An Assessing Officer's failure to examine that binding circular constitutes inadequate inquiry, rendering an assessment erroneous and prejudicial to the Revenue. The notes further state that prevailing High Court decisions did not recognise BOT-road development expenditure as creating a depreciable intangible asset; therefore, contrary Tribunal reasoning was not a sustainable possible view. Revision of the assessment under Section 263 was accordingly valid. en-us Wed, 28 Jan 2026 00:00:00 +0530 Fri, 07 Aug 2026 09:07:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796577 Depreciation on BOT toll-road development cost was not allowable merely by treating toll-collection rights as an intangible asset. The notes state that, where road ownership does not vest in the assessee, CBDT Circular No. 9/2014 requires the development cost to be amortised over the concession period. An Assessing Officer's failure to examine that binding circular constitutes inadequate inquiry, rendering an assessment erroneous and prejudicial to the Revenue. The notes further state that prevailing High Court decisions did not recognise BOT-road development expenditure as creating a depreciable intangible asset; therefore, contrary Tribunal reasoning was not a sustainable possible view. Revision of the assessment under Section 263 was accordingly valid. Case-Laws Income Tax Wed, 28 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796577