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2014 (7) TMI 300 - AT - Income TaxValidity of reassessment u/s 147 of the Act – Valuation of closing stock - Held that:- on perusal of the order of CIT(A) itself it becomes clear that the assessee has raised a specific ground with regard to validity of proceeding u/s 148 of the Act. However, as it appears from finding of the CIT(A) in para 5 of his order, he has not decided the issue on merit. - matter remanded back. Undervaluation of closing stock - CIT(A) has concluded that 1% of closing stock determined by the Assessing Officer is to be treated as under valuation made by the assessee. - Held that:- Though on one hand the CIT(A) has upheld Assessing Officer’s finding that closing stock for the year ending was understated but at the same time, he has not agreed with the quantum worked out by the Assessing Officer. It is also pertinent to mention here that in para 4.2.4, the CIT(A) while observing that both the assessee as well as the Assessing Officer were correct in working out the value of the closing stock for the year ending 31/03/2006, in the same breath has observed that both of them were wrong in quantifying closing stock. – matter remanded back for fresh decision.
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