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Issues Involved:
1. Acceptance of change in the method of valuation of closing stock. 2. Comparison between Direct Costing and Absorption Costing methods. 3. Compliance with Accounting Standards and Supreme Court precedents. Detailed Analysis: Issue 1: Acceptance of Change in the Method of Valuation of Closing Stock The revenue objected to the change in the method of valuation of closing stock from Absorption Cost to Direct Cost, accepted by the CIT (Appeals). The revenue argued that Absorption Cost provides a true value of the stock on hand, while Direct Cost does not. They contended that continuous valuation at a lesser value would result in under-valuation of the stock by Rs. 2.21 Crores. The appellant company had historically valued its closing stock on 'lower of cost or realisable value' using 'total cost' but later modified the term 'cost' to mean 'direct cost'. The company's method included costs of raw materials, stores, and variable costs of manufacture, excluding fixed costs like administration, reasoning that fixed costs do not contribute to production. Issue 2: Comparison between Direct Costing and Absorption Costing Methods The appellant company supported its method with an opinion from a Cost Accountant, who examined the system against the standard prescribed by the Institute of Chartered Accountants of India (AS-2). The Cost Accountant concluded that neither the previous nor the current method strictly adhered to the prescribed standards. He found that Direct Costing, which includes raw materials, incidental materials, stores, and variable costs, was more appropriate for the appellant due to production fluctuations and the impracticality of fixing normal production levels. Absorption Costing, which includes both variable and fixed costs, was deemed cumbersome and subjective. The Cost Accountant recommended Direct Costing, excluding fixed costs such as wages of employees paid on a fixed basis. Issue 3: Compliance with Accounting Standards and Supreme Court Precedents The appellant company's method of Direct Costing was argued to be in conformity with the prescribed standards of the Institute of Chartered Accountants of India. The revenue did not dispute the appropriateness of Direct Costing but preferred Absorption Costing. The Tribunal reviewed the definitions of 'direct costing', 'absorption costing', and 'variable costs' as per AS-2, which allows for inventory valuation based on either method, provided it reflects the true value. The Tribunal emphasized that Direct Cost should include all costs directly related to production, including direct labour. The Tribunal referenced the Supreme Court's decision in CIT v. British Paints India Ltd., noting that the appellant's method differed as it included variable costs, making the Supreme Court's ruling inapplicable. The Tribunal concluded that the exclusion of direct labour costs of own employees by the appellant did not reflect the true direct cost of goods produced. It was held that the choice between Direct Costing and Absorption Costing rests with the assessee, provided the inventory reflects its true value. The Tribunal cited the Madras High Court in CIT v. Carborandum Universal Ltd., which upheld the Direct Costing method, including direct labour costs, as a recognized principle of inventory valuation. The Tribunal ruled that the revenue could not impose Absorption Costing over Direct Costing, except for modifying the Direct Costing method to include direct labour costs of own employees. The Tribunal found that the appellant's method, with necessary modifications, complied with section 145 of the Act, making the Supreme Court's decision inapplicable. Conclusion: The Tribunal upheld the change in the method of valuation of closing stock to Direct Costing, with the modification to include direct labour costs of own employees, and ruled that the revenue could not impose Absorption Costing. The appellant's method was found to be in compliance with the prescribed accounting standards and consistent with judicial precedents.
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