2001 (10) TMI 50

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..... year 1991-92. It declared a loss of Rs.7,52,53,863. On December 7, 1992, the Assessing Officer completed the assessment and made an addition of Rs.10,63,977 on account of the revaluation of the closing stock. This addition was made on the hypothesis that the valuation of the closing stock had to be done on the basis of the average price for the month of March, 1991. Thus, the final figure of loss .....

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..... 260A of the Income-tax Act, 1961. Mr. Sawhney, learned counsel for the Revenue, contends that the value of the closing stock had to be fixed on the basis of an average sale price for the month of March, 1991. This was Rs.763.51. The assessee had fixed the value of the stock at Rs.753.83 per bag. The method adopted by the assessee was illegal. Thus, the addition was validly made. The Tribunal ha .....

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..... would have contended before the Tribunal that the assessee has accepted the addition. Otherwise, the Revenue does not give the benefit. So, it wants the best of both the sides. Still further, it appears to us that the Revenue is only trying to fiddle with the figures. In fact, the addition to the value of the stock in hand has not resulted in any loss to the Revenue. The value which has been shown .....

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