Constitutionality and legality of Income Computation and ...

Tax authorities mandating FIFO/Average Cost for inventory valuation, excluding LIFO method.

Case Laws     Income Tax

November 6, 2024

Constitutionality and legality of Income Computation and Disclosure Standards (ICDS) II and Notification 87/2016, which mandate the use of the First In First Out (FIFO) or Weighted Average Cost method for inventory valuation, excluding the Last In First Out (LIFO) method, while computing income under the head of Profits and Gains of Business or Profession under the Income Tax Act. The court held that FIFO, LIFO, and Weighted Average Cost are recognized methods for inventory valuation, and the adoption of any particular method aims to reflect the fairest approximation of the cost incurred. The valuation of unsold stock is a necessary process for determining trading results, not the source of profits. The amendment to Section 145A and ICDS II were not manifestly arbitrary, as they aimed to provide a uniform method of inventory valuation for assessees computing income under the specified head. The court found no unreasonable classification or violation of the equal protection rule, as the prescription applies to all assessees in the specified category. The appellants cannot claim a fundamental right to follow a particular inventory valuation method that would prevail over statutory prescription. The decision to amend Section 145A and implement ICDS II was based on recommendations from expert financial bodies.

View Source