This topic has been debated quite a lot recently on planted tank forums.
My personal belief is if you are using pressurized CO2, there should always be a certain amount of surface movement. Yes, when plants pearl during the lighting period there is plenty of O2 available. But, as andywg stated, things change at night. Having a bit of surface movement won't cost that much extra in CO2 anyway. Some people have no noticeable surface movement and inject CO2. If you don't create agitation at night in these circumstances you may be asking for trouble. I've seen countless posts on forums from people who inject CO2, wake up to a tank full of dead and dying fish and blame the CO2. Sure, sometimes the CO2 is to blame, but sometimes it may be due to a lack of O2.
Here is part of a post from someone who tested the dissolved oxygen levels in his planted tank
"I dug out some dissolved oxygen (DO) numbers for my 29g jungle tank that can provide a bit of numerical perspective. The tank has pressurized CO2 with no surface agitation, good internal flow, low pollution, and is moderately overstocked. It’s covered by a glass partition such that there’s a 1/2” strip in front and 3/4” strip in back open to the atmosphere. I run it a bit cool, at 72F => saturated DO ~8.7ppm .
4wpg lighting
a) morning ppm 6.6
evening ppm 13.7
next morning ppm 6.6 (no overnight aeration)
b ) morning ppm 7.4
evening ppm 13.0
next morning ppm 8.2 (continuous high level overnight aeration)
c) morning ppm 8.2
evening ppm 14.8
next morning ppm 7.8 (continuous modest overnight aeration)
2wpg lighting
d) morning ppm 4.1
evening ppm 6.9
next morning ppm 4.1 (no overnight aeration)
It's obvious that when photosynthesis is really kicking during the day (a,b,c), DO is high the next morning. It’s significantly higher if overnight aeration is provided however. Under conditions of low light reduced photosynthesis during the day (d) DO is quite low the next morning. If the tank were even more overstocked, more polluted, or covered, DO would be even lower under low light, possibly approaching dangerous levels for the fish. DO concentrations of 5-6 ppm are generally recommended for good fish health with saturation levels possibly even better. Fish are severely stressed at <2-3ppm and will die at <1ppm"
HTH.