2014 (1) TMI 929 - AT - Income Tax

Stock in transit not included under closing stock Escapement of income - Held that - There was no infirmity in the above reasoning given by the CIT(A) for deleting the addition made by the Assessing Officer - In the absence of any justification for disturbing the method of accounting regularly followed by the assessee with regard to non-inclusion of the stock in transit in the closing stock, the Assessing Officer is not justified in concluding in the first place that income chargeable to tax has escaped assessment. There is no case for the Revenue to make the addition on account of under-valuation of closing stock, by the cost of stock in transit only in the year under appeal, having found no fault in the method of accounting followed by the assessee, and consequently not made any such addition in the earlier years - addition made by including the stock in transit in the closing stock, without making corresponding adjustments in the stock figures of earlier years, the accounts of the assessee would reflect for the year under appeal a distorted picture - any adjustment to the closing stock would have its corresponding impact in the opening stock of the succeeding year - such an adjustment to the closing stock in the first place is of no significance Decided against Revenue.

Issues:
1. Interpretation of accounting treatment for stock in transit in closing stock.
2. Assessment of income based on accounting method consistency.
3. Justification for inclusion of stock in transit in closing stock.
4. Impact of adjustment to closing stock on succeeding year's opening stock.

Analysis:
1. The appeal by the Revenue challenged the CIT(A)'s order concerning the assessment year 2005-06, specifically focusing on the treatment of stock in transit in the closing stock. The Assessing Officer proposed an addition to the closing stock due to the non-inclusion of stock in transit, leading to a difference of Rs.2,35,17,591. The CIT(A) observed the regular practice of the assessee to account for stock in transit only upon receipt, not at the year-end, and concluded that the method should not be disturbed based on a single year's assessment. The CIT(A) deleted the addition, emphasizing that any adjustment to closing stock would have a corresponding impact on the opening stock of the succeeding year.

2. The core issue revolved around the consistency of the assessee's accounting method regarding stock in transit and its impact on the assessment of income. The CIT(A) noted that the Assessing Officer failed to demonstrate how the assessee's method consistently resulted in income escapement. The CIT(A) reasoned that disturbing the accounting method for a single year without evidence of systematic under-assessment was unwarranted. The Tribunal upheld the CIT(A)'s decision, highlighting that the Revenue had not raised similar concerns in prior years, indicating a lack of substantial impact on the overall assessment.

3. The Assessing Officer contended that the stock in transit should be included in the closing stock, leading to the proposed addition. However, the CIT(A) and the Tribunal disagreed, emphasizing the assessee's consistent practice of accounting for stock in transit upon receipt. The Tribunal found no justification for including stock in transit in the closing stock for the specific assessment year, especially considering the lack of evidence showing systematic under-assessment due to this accounting treatment.

4. The Tribunal's decision underscored the interplay between adjustments in closing stock and their subsequent impact on the opening stock of the following year. By rejecting the Revenue's appeal and upholding the CIT(A)'s order, the Tribunal emphasized the lack of significance in making isolated adjustments to closing stock without corresponding modifications in earlier years. The Tribunal's analysis focused on maintaining consistency in accounting practices to avoid distorting the financial picture reflected in the assessee's accounts.

In conclusion, the Tribunal dismissed the Revenue's appeal, affirming the CIT(A)'s decision to delete the addition related to stock in transit in the closing stock for the assessment year 2005-06. The judgment highlighted the importance of consistent accounting methods and the lack of substantial impact on income assessment from the assessee's treatment of stock in transit.

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