9911796707
TMI Blog2012 (11) TMI 101X X X X Extracts X X X X X X X X Extracts X X X X ..... record perused. From record we find that the assessee is engaged in the business of ginning and pressing of cotton. During the course of scrutiny assessment, the Assessing Officer found that the method of valuation of closing stock was changed from market price to cost or net realizable value whichever is lower which resulted into reduction of profit by Rs. 9,88,363, therefore, the Assessing Officer added the difference to the returned income. 3. By the impugned order, the Commissioner of Income Tax (Appeals) deleted the addition after having the following observations :- "4.1 Ground no. 1 is against the addition of Rs.9,88,363/- on account of undervaluation of closing stock. Copies of submissions made before the A.O. on this point vide a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... justifiable as it could not fully convince the reason for deviation in method of valuation of closing stock. The appellant having given such a cogent explanation supported by relevant details, it was for the A.O. to specifically state as to what was wanting in the appellants explanation and while it was not justified or as to how it could not fully convince the A.O. with the reason for deviation in the method of valuation of closing stock. For this reason, the A.O.'s order and finding in the matter is nonspeaking. Alongwith voluminous details filed by the ld. AR, copy of my predecessor's order dated 13.02.2004 in Appeal No. IT-121/03- 04/474 in the case of M/s Satyam Cotex P(Ltd.), a group concern for A.Y. 2001-02 is also filed. After taki ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... standards to be followed by any class of assessees u/s 145(2) of the Act. Sub-para 9 of said Notification reads as under :- "A change in an accounting policy shall be made only if the adoption of a different accounting policy is required by statute or if it is considered that the change would result in a more appropriate preparation or presentation of the financial statements by an assessee." Thus, it is clear that bonafide change in the method of valuation of closing stock, as suggested by AS-2, has not been denied anywhere. The detailed finding recorded by Commissioner of Income Tax (Appeals) to the effect that the assessee's explanation of the difference in valuation of closing stock is quite clear, convincing and comfortable to the ac ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
