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TMI Blog1992 (3) TMI 101X X X X Extracts X X X X X X X X Extracts X X X X ..... of its stock of finished goods of industrial machinery and Glass Lined Equipments from "sold at contract rate and unsold at lower of the cost or market value" to 'At cost'. As a result of this change the valuation of closing stock of Industrial Machinery and Glass Lined Equipments was lower by Rs. 7,30,298. It was submitted by the assessee that the assessee had changed method because the changed method was proper method and also proper method. It was submitted that the change has been made on permanent basis and the changed method had been followed in all subsequent years. It was also submitted that the changed method was a recognised method acknowledged by the Accounts and Commercial World. It was also submitted that the change was bona f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessee for valuing closing stock, was a recognised method of valuation and was a proper method and the said method had been following permanently in subsequent years. He referred to the decision of the Calcutta High Court in the case of British Paints India Ltd. v. CIT [1978] 111 ITR 53. According to him the closing stock of the year under consideration would be opening stock of the subsequent year and the loss, if any, would get set off in subsequent years and there would be no loss to the revenue in view of the fact that rate of tax in the case of companies are uniform over the years. He accordingly deleted the addition made by the ITO. The department is in appeal before the Tribunal. 10. After hearing the parties, we find that t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in which the change take place. This decision supports the view which we have taken. We may mention here that Special Leave Petition filed by the department against the said decision of the Madras High Court has been dismissed by the Supreme Court. 11. Before parting, we may mention that the department had relied on the decision of the Delhi High Court in the case of K.G. Khosla Co. (P.) Ltd. v. CIT [1975] 99 ITR 574. That decision is of no assistance. In that case opening stock of goods had been valued at cost plus customs duty and charges while closing stock was valued without adding customs duty and charges and the value of closing stock was disturbed in these circumstances by adding customs duty and charges. It was held that the ac ..... X X X X Extracts X X X X X X X X Extracts X X X X
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