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TMI Blog2019 (7) TMI 1193X X X X Extracts X X X X X X X X Extracts X X X X ..... he ITAT that in the present case the AO had indeed undertaken a detailed inquiry into the aspect of valuation of stock and that, therefore, the requirements for assumption of jurisdiction by the CIT under Section 263 of the Act were not fulfilled. The Court does not find any substantial question of law arising from the impugned order of the ITAT. The appeal is accordingly dismissed. - ITA 677/2019 - - - Dated:- 22-7-2019 - S. MURALIDHAR AND TALWANT SINGH JJ. Appellant Through: Mr. Zoheb Hossain Senior Standing Counsel and Mr. Deepak Anand Junior Standing Counsel for the Revneue. Respondents Through: Mr. Kislaya Parashar, Mrs. Mekhala Benny and Miss Umang Luthra Advocates. O R D E R C. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... power under Section 263 of the Act and issued a show cause notice ( SCN ) to the Assessee on 11th July, 2016 where the focus was on valuation of the stock with the Assessee. It was noted by the CIT that as per the inventory, the total stock was valued at ₹ 33,48,49,952/- and excess stock was valued at ₹ 15,95,72,922/-. According to the CIT, the AO failed to properly investigate the issue concerning the excess un-accounted stock of ₹ 9,95,72,922/-. Further, with regard to the difference of ₹ 55,37,754/- for diamond jewellery, the AO had simply accepted the reply of the Assessee that the valuer had valued artificial stones at the rate of diamonds and this had caused the difference in valuation. In the order dated 27 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e on the part of the AO to conduct a proper inquiry into the question of difference in the valuation of the stock and that the case fell within the parameters for interjection under Section 263 of the Act as expressed by the Supreme Court in CIT v. Amitabh Bachhan (2016) 11 SCC 748. 8. Having heard learned counsel for the Revenue, and having examined the orders discussed hereinbefore, this Court is not persuaded to conclude that the impugned order of the ITAT suffers from any legal infirmity. In particular, this Court concurs with the view of the ITAT that in the present case the AO had indeed undertaken a detailed inquiry into the aspect of valuation of stock and that, therefore, the requirements for assumption of jurisdiction ..... X X X X Extracts X X X X X X X X Extracts X X X X
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