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TMI Blog2014 (5) TMI 428X X X X Extracts X X X X X X X X Extracts X X X X ..... al addition sustained by the CIT(A) at Rs.23,26,514 - It would be just and reasonable to allow such telescoping in order to ensure that the same income is not taxed twice – Decided against Revenue. - ITA No. 5504/Mum/2012 - - - Dated:- 30-4-2014 - Shri D. Manmohan And Shri N. K. Billaiya, AM,JJ. For the Appellants : Shri Ganesh Bare For the Respondent : Shri Shriram Bajaj ORDER Per N. K. Billaiya, AM: This appeal by the revenue is directed against the order of the CIT(A)-27, Mumbai, dated 26.06.2012 pertaining to A.Y. 2008-09. The grievances of the revenue read as under: 1. On the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in deleting and sustaining the value of closing stock ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lief in respect of mistake of calculation of stock to the tune of Rs.31,30,192/- The AO proceeded to allocate indirect cost, salary wages, partners remuneration and conveyance travelling expenses to determine the valuation of inventory as on 31.03.2008 by making an upward adjustment of 10% towards direct cost amounting to Rs.29,40,192 and completed the assessment by making additions in respect of the direct related cost of inventory Rs.29,40,120/-, subsequent purchase bill amount of Rs.14,12,050/- and disallowing calculation errors at Rs.31,30,192/- The assessee carried the matter before the CIT(A). 3. It was reiterated before the CIT(A) that the survey authorities have not calculated the stock properly. It was further explained that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... towards direct cost related to the inventory is in order to the extent of Rs.9,14,400/- It was further explained to the CIT(A) that the AO has not considered the reconciliation of purchases. It was explained that certain bills were received post survey but the corresponding goods were received on or before the date of survey. A reconciliation of purchase was furnished before the CIT(A), which is incorporated at page 11 of the first appellate authority s order. After considering the reconciliation statement the CIT(A) was of the opinion that when all other figures were allowed to be corrected at the time of assessment proceedings, therefore the same view should be adopted so far as the purchases are concerned. According to the CIT(A) the dis ..... X X X X Extracts X X X X X X X X Extracts X X X X
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