https://www.taxtmi.com/caselaws?id=796577 Revision under Section 263 was valid because the assessment allowed depreciation on BOT toll-road development cost as an intangible asset without examining the binding CBDT Circular requiring amortisation over the concession period where road ownership does not vest in the assessee. Failure to apply the circular constituted inadequate inquiry. Prevailing High Court decisions also treated BOT-road development expenditure as not creating a depreciable intangible asset, so acceptance of a contrary Tribunal view was not a sustainable possible view. The assessment was therefore erroneous and prejudicial to Revenue interests, supporting revision. 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 Revision under Section 263 was valid because the assessment allowed depreciation on BOT toll-road development cost as an intangible asset without examining the binding CBDT Circular requiring amortisation over the concession period where road ownership does not vest in the assessee. Failure to apply the circular constituted inadequate inquiry. Prevailing High Court decisions also treated BOT-road development expenditure as not creating a depreciable intangible asset, so acceptance of a contrary Tribunal view was not a sustainable possible view. The assessment was therefore erroneous and prejudicial to Revenue interests, supporting revision. Case-Laws Income Tax Wed, 28 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796577