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TMI Blog2015 (4) TMI 839X X X X Extracts X X X X X X X X Extracts X X X X ..... g had been altered with effect from the Assessment Year 2001-02. However, the facts reveal that the write off was on account of deterioration in the condition of the non-moving stores since the assessee's plants were located in remote places and near the sea. The non-moving stores and spares were corroded over a period of time due to wear and tear. This method of accounting having been adopted in the earlier years, there was no reason for the Assessing Officer to disallow the same on the ground that the accounting method had changed. Accordingly, we are of the view that the Judgment of this Court in the case of Heredilla Chemicals [1997 (1) TMI 66 - BOMBAY High Court] will not affect the write off by the assessee in the present case bein ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... imed towards loss of nonmoving stores could not be so claimed in view of the fact that the assessee was believed to have changed its method of accounting in respect of stores and spares, inasmuch as it wrote off 95% of the value of such stores and spares which had not moved over the last three years and retained only 5% of the residual value. The Assessing Officer was of the view that no specific reasons were mentioned for change of method of accounting. He relied upon the decision of this Court in the case of CIT Vs. Heredilla Chemicals Ltd., reported in (1997) 225 ITR Page 532, in which case an item known as PAN catalyst was found to have become superfluous and obsolete and it was neither sold or disposed of by the assessee but merely w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessee, a Government of India Company, was subject to audit by the Comptroller and Auditor General of India. The market value of the damaged goods was pegged at 5% and the valuation deducted by the assessee had been accepted by the Comptroller's office. Furthermore, the Department had not seriously disputed the value so determined. There was no attempt on the part of the Revenue to establish otherwise and that being so the Comptroller and Auditor General having accepted the valuation of the closing stock, there was no reason to take a different view. 6. The Tribunal distinguished the case of Heredilla Chemicals (supra) on facts. In Heredilla Chemicals the assessee had purchased the PAN catalyst plant which was kept as a standby. Ove ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... further adjusted to include the amount of any tax, duty, cess or fee (by whatever name called) actually paid or incurred by the assessee to bring the goods to the place of its location and condition as on the date of valuation. Explanation.- For the purposes of this section*, any tax, duty, cess or fee (by whatever name called) under any law for the time being in force, shall include all such payment notwithstanding any right arising as a consequence to such payment; (b) interest received by an assessee on compensation or on enhanced compensation, as the case may be, shall be deemed to be the income of the year in which it is received.] 8. In our view, the objection raised by the assessee on account of the method of accounting is ..... X X X X Extracts X X X X X X X X Extracts X X X X
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