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TMI Blog2015 (11) TMI 1294X X X X Extracts X X X X X X X X Extracts X X X X ..... adopted for the purpose of valuing closing stock. In the light of this different stand taken before the Assessing Officer, he had no option but to adopt one of the permissible methods for valuation of closing stock. The method of calculation under FIFO method made by the Assessing Officer was not found fault by the appellant. Since the appellant had miserably failed to demonstrate before us that it was following continuously weighted average cost method for the purpose of valuation, we have no option but to confirm the action of the Assessing Officer in this regard. - Decided against assessee - ITA No. 2647/Del/2013 - - - Dated:- 2-9-2015 - SMT. DIVA SINGH, JUDICIAL MEMBER AND SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER For The Appella ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sessment proceedings without appreciating the facts and material on records. 2. Briefly stated facts of the case are that the appellant company is engaged in business of manufacturing and sale of gold and silver ornaments. The return of income was filed for the assessment year 2009-10 on 29.09.2009, disclosing loss of ₹ 1,98,806/-. The case was selected for scrutiny assessment and finally the assessment was completed under section 143(3) of the Income-tax Act, 1961 (for short the Act ) at a total income of ₹ 11,65,390/- vide order dated 28.12.2011. The disparity between the returned income and the assessed income is on account of addition of ₹ 13,64,195/- on account of undervaluation of stock. The Assessing Officer mad ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Further, as per the general market practice and trend, FIFO method must be employed to evaluate the correct value of stock, therefore on the basis of given facts and circumstances, the submission of the assessee is not found to be enable, hence rejected. In view of the facts as discussed above, the value of closing stock is considered at ₹ 12106107/- in place of ₹ 10741912/- (as discussed above). Therefore, difference of ₹ 13,64,195/- (12106107- 10741912) in the value of closing stock as calculated above is considered the income of the assessee for the year under consideration. Accordingly, addition of ₹ 13,64,195/- is made on account undervalued the stock by the assessee. From the above observation of the AO i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... considering the weighted average cost method was followed for the purpose of valuing the closing stock and therefore he submitted that no addition was called for on account of this item. 4. On the other hand, learned Senior DR relied on the orders of the authorities below. 5. We have heard the rival submissions and perused the material on record. The Assessing Officer made addition on account of valuation of closing stock by following FIFO method which is one of the accepted methods of valuation of closing stock. The appellant had adopted inconsistent stand, on one hand he submits that he was following FIFO method, and on the other hand he submits that he followed weighted average cost method. In the Tax Audit Report, it was stated t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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