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Issues Involved:
1. Change in the method of valuing closing stock. 2. Validity of the new method of valuation. 3. Impact of the change on the duty drawback/proforma credit. Detailed Analysis: 1. Change in the Method of Valuing Closing Stock: The primary issue in this appeal is the change in the method of valuing the closing stock by the assessee-company. The Assessing Officer (AO) noted that the company altered its valuation method from weighted average cost based on invoice value to a method considering duty drawback received. This change led to a decrease in the inventory value by Rs. 24,14,000, increasing the reported loss by the same amount. 2. Validity of the New Method of Valuation: The CIT(A) found the change in valuation method to be bona fide, as it was consistently followed in subsequent years. The difference between the old and new methods was the reduction of proforma credit received from the Excise authorities for valuing the closing stock, which was not done in earlier years. The CIT(A) relied on several judicial precedents to support the permissibility of such a change, including decisions from the Calcutta and Madras High Courts. The Tribunal examined the details provided by the assessee, including a hypothetical example illustrating the impact of the new valuation method. The example showed that the new method resulted in a lower closing stock value, which corresponded to the Rs. 24.14 lakhs difference noted in the accounts. The Tribunal found that the new method followed one of the acceptable accounting standards prescribed by the Institute of Chartered Accountants of India (ICAI). 3. Impact of the Change on Duty Drawback/Proforma Credit: The AO's contention was that the assessee had not justified the change in the valuation method and had arbitrarily altered it to suit its purposes. The CIT(A), however, accepted the change as bona fide. The Tribunal clarified that the reference to duty drawback was a misnomer, as the assessee did not export goods and thus did not receive duty drawback. Instead, the assessee received proforma credit under the Excise law, which was similar to the MODVAT scheme. The Tribunal noted that the method of valuing the closing stock should conform to accepted accounting standards. The assessee's method, which credited the proforma credit to the raw materials account and adjusted it against excise duty on finished goods, was found to be substantially in line with one of the methods suggested by ICAI. Although the assessee did not strictly follow the prescribed accounting method, the Tribunal concluded that there was no revenue effect due to the method adopted. The Tribunal upheld the CIT(A)'s order, affirming that the change in the method of valuation was bona fide and in conformity with accepted accounting principles. The appeal was dismissed. Conclusion: The Tribunal upheld the CIT(A)'s decision, recognizing the change in the method of valuing closing stock as bona fide and in accordance with accepted accounting standards. The appeal was dismissed, affirming the permissibility of the new valuation method and its consistency with the principles laid out by ICAI.
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