Section 263 Revision Not Sustainable for mere Inadequacy of Enquiry /Insufficiency of Material on Record

CIT Vs Cyber Park Development & Construction Ltd. (Karnataka High Court) The issue under consideration is whether mere inadequacy of an enquiry or insufficiency of material on record can be a ground to invoke revisional powers u/s 263 of the Income Tax Act, 1961? High Court states that, the Tribunal has found that the Assessing Officer on meticulous appreciation of evidence on record has allowed depreciation on intangible assets and the Commissioner of Income Tax (Appeals) while passing the order under Section 263 of the Act has held that the enquiry and verification made by the Assessing ...