9911796707
TMI Blog1997 (5) TMI 22X X X X Extracts X X X X X X X X Extracts X X X X ..... on the facts and in the circumstances of the case, the Tribunal is right in law in deleting the addition of Rs. 12,31,658 made by the AO and upheld by CIT(A) on account of valuation of closing stock of sugar." 2. M/s Janta Co-operative Sugar Mills Ltd., Bhogour, manufactures three different varieties of sugar, i.e., crystal sugar, raw brown sugar and sugar in process and for each variety of sugar different method was adopted for valuing the same on the last day of the accounting year. For crystal sugar, it put value of production @379.96 per bag; for raw brown sugar it valued the stock @Rs. 150 per bag and for sugar in process it valued the stock @Rs. 90 per bag. In its return filed on 3rd March, 1984, the assessee-firm declared a loss o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n. 3. We have heard the learned counsel for the parties. 4. The assessee-firm was asked to explain the basis for valuation of sugar manufactured by it. As per statement submitted before the IAC (Asst.) Range I, Jalandhar, the assessee had declared 45309 bags of free sale sugar and the value was calculated @ Rs. 383 per bag. The IAC (Asst.) Range I, Jalandhar, worked out the cost of production, as regards crystal sugar, at Rs. 383 per bag as against Rs. 379.96 adopted by the assessee and accordingly he made an addition of Rs. 1,37,727 in respect of this variety of sugar. Similarly, as regards other two varieties of sugar, i.e., raw brown sugar and sugar in process, additions of Rs. 7,63,308 and Rs. 5,90,385, respectively, were made b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , raw brown sugar and sugar in process after holding that the assessee had followed a regular and accepted method of valuing its closing stock over a number of years, which was being accepted in the earlier years as also in the later years. We would not like to give our opinion as regards the method adopted by the authorities below for arriving at a particular value for manufacturing three types of sugar in stock with the assessee-firm at this stage. We find that the Tribunal has not given any cogent reasons for accepting the method of valuation in regard to the closing stocks of the assessee-firm and it based its findings only on the practice in this regard followed by the assessee-firm during the earlier years. Therefore, we are of the op ..... X X X X Extracts X X X X X X X X Extracts X X X X
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