2012 (11) TMI 393 - AT - Income Tax

Unaccounted expenditure u/s 69 C - Held that - Even though, the assessee has reasoned out in various ways but he has not produced the actual and accurate working for the valuation of work in progress - further, to justify the assessee s claim that it has valued the work in progress on the basis of market value the assessee has not submitted any valuation report. Therefore, the decision of the cases relied upon by the assessee are not applicable to its facts of the case. Looking at the complexity of the issue & on an overall examination of the facts an addition of Rs.30,00,000/- as against Rs.61,44,189/- done by CIT(A) requires to be sustained to meet the end of justice - partly in favour of assessee.

Summary

Issues:
1. Discrepancies in the valuation of work-in-progress (WIP) of incomplete moulds.
2. Addition of unexplained expenditure under section 69C of the Income Tax Act.
3. Assessment of the valuation of WIP and determination of manufacturing cost.
4. Appeal against the order of the CIT-(A) regarding the addition of unexplained expenditure.

Discrepancies in the valuation of work-in-progress (WIP) of incomplete moulds:
The assessee, a Private Limited Company engaged in manufacturing, declared total income for AY 2006-07. The Assessing Officer (AO) noted discrepancies in the WIP valuation for incomplete moulds, leading to an addition of unexplained expenditure under section 69C of the Income Tax Act. The AO compared WIP values for different financial years and manufacturing costs, concluding that unexplained expenditure of Rs.1,22,88,377/- was incurred. The CIT-(A) partially confirmed the addition, sustaining Rs.61,44,189/- based on the high valuation of WIP. The assessee argued that the valuation was based on market rates and profit margins, denying unaccounted expenditure. The ITAT sustained an addition of Rs.30,00,000/- as an estimate to meet the ends of justice, dismissing the revenue's appeal.

Addition of unexplained expenditure under section 69C of the Income Tax Act:
The AO invoked section 69C due to discrepancies in WIP valuation, deeming unexplained expenditure as the assessee's income. The CIT-(A) and ITAT analyzed the valuation method, profit margins, and lack of evidence supporting unaccounted expenditure. The ITAT reduced the addition to Rs.30,00,000/-, emphasizing the need for accurate working and valuation reports to justify claims.

Assessment of the valuation of WIP and determination of manufacturing cost:
The AO calculated manufacturing cost based on WIP valuation discrepancies, leading to the addition under section 69C. The assessee argued that the high WIP valuation was justified by market rates and profit margins, challenging the presumption of unexplained expenditure. The ITAT emphasized the importance of accurate working and valuation reports to support claims and justify WIP values.

Appeal against the order of the CIT-(A) regarding the addition of unexplained expenditure:
The CIT-(A) partially confirmed the addition of unexplained expenditure, considering the high WIP valuation and profit margins. The ITAT further reduced the addition to Rs.30,00,000/- on an estimate basis, dismissing the revenue's appeal. The ITAT highlighted the need for accurate working and valuation reports to support claims and justify WIP values for fair assessment.