9911796707
TMI Blog2020 (6) TMI 664X X X X Extracts X X X X X X X X Extracts X X X X ..... erred in confirming the following actions of the Assessing Officer in :- i. completing assessment under section 143(3) of the Income Tax Act, 1961 ('the Act') determining taxable income at Rs. 24,66,44,620/- against returned income in a sum of Rs. 21,76,39,230/-; ii. making addition of Rs. 2,90,05,390/- on account of valuation in closing stock rejecting the method of valuation adopted by the assessee, accepted by the Department from year to year in the past by rejecting the method of valuation of closing stock on estimate basis." 3. The assessee has also raised additional ground of appeal which reads as under:- "On the facts and in the circumstances of the case and in law, and without prejudice to the original grounds as raised in t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... @ 25% to arrive at the value of closing stock. The assessee explained that it was following the said practice for past several years and the same has been accepted as such. The Assessing Officer was of the view that there was no basis for adopting 25% as the basis of discount for computing the value of closing stock. He was of the view that the income of the assessee needs to be re-computed in terms of section 145(3) of the Act after re-valuing the closing stock. He adopted the average G.P. rate of past two years @ 9.22% and applied rate of 9.22 % for computing the value of closing stock, which resulted in making an addition of Rs. 2,90,05,390/-. The CIT(A) confirmed the same against which the assessee is in appeal before us. 6. The Ld.A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... finished goods/finished goods was determined on the basis of sale value less 25%. The raw material was valued at cost. The Assessing Officer questioned the method of valuation adopted by the assessee. In reply, it was pointed out that the said method has been adopted from year to year by the assessee. The Assessing Officer rejected the same and noted that the G.P. rate declared by the assessee in Assessment Year 2014-15 was 9.38% and in Assessment Year 2015-16 was 9.07% and adopting the average of 9.22%, the Assessing Officer worked out the value of closing stock at Rs. 16.68 crores (approx.). This resulted in an addition of 2.90 crores (approx.). The plea of the assessee before us is that where consistent method has been followed from year ..... X X X X Extracts X X X X X X X X Extracts X X X X
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