Revision for unexamined depreciation fails where assessment records show inquiry and no revenue prejudice from amortisation timing.

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....Revision for alleged lack of inquiry into depreciation on toll-collection and sea-link operation rights was unsupported where the assessment record contained notices, details of the intangible-asset investment, the concession agreement and the depreciation claim. CBDT Circular No. 9/2014 concerning expenditure incurred by a BOT road or highway developer did not apply to a non-developer concessionaire that acquired toll-collection, operation and maintenance rights. As the cost was deductible through either depreciation or amortisation, the difference concerned timing and caused no real prejudice to revenue. The revision was quashed and the original assessment restored.....