1994 (12) TMI 120

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..... unt was made in the revised return filed on5th Dec., 1983but the said claim was not considered by the Assessing Officer (AO). The learned CIT(A) noted that the assessee had already lost as this issue right up to the Tribunal stage in earlier years and the issue was pending before the Hon'ble High Court. All the same, the learned CIT(A) in the circumstances, directed the AO to consider the claim made by the assessee after giving the assessee an opportunity of being heard. The assessee is aggrieved. 4. We have heard the learned representatives. On a mere perusal of relevant facts it is to be held that the assessee under the circumstances cannot have a grievance on this account when the learned CIT(A) has already directed the AO to consider .....

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..... ck. Here the relevant facts are that the assessee is engaged in the business of manufacturing bicycles and parts for the last 25 years. During the relevant previous year, it appointed a committee of experts to determine the correct value of old and obsolete stock which had been piling up since the inception of its business when it was felt that the assessee's book results were getting distorted. The committee so appointed made its recommendations and suggested itemswise reduction in the value of stocks both of raw-material and of stores and spares. The assessee on the basis of recommendations of this committee reduced the value of its such stocks of raw-material by an amount of Rs. 1,60,453 and that of stores and spares by an amount of Rs. .....

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..... d was far less than what was being disclosed in the books. The committee recommended reduction in the value of each and every item involved as a result of which a total amount of Rs. 2,90,299 was reduced from the value of such stocks by charging it to P L account. He submitted that a conscious and bona fide decision was taken to change the method of valuation of such stocks due to business necessity and the same method continued to be followed subsequently as also the reduced value was taken as value of opening stock as on the first day of the following previous year. It was accordingly submitted that on these facts and under these circumstances, the claim made was bona fide and, therefore, allowable. In support of his proposition, the lear .....

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