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2014 (4) TMI 390 - AT - Income TaxDifference in valuation of stock – Held that:- The assessee explained the difference of stock and the difference was on account of stock being valued at MRP instead of at cost - the assessee also produced the purchase bills and invoices - Considering the purchase invoices and bills, the value of stock was reduced to Rs.1.08 crores i.e., by adopting the gross profit rate of 11.5% - the difference in stock was determined at Rs.27 lakhs - what the assessee offered at the time of survey on 30.03.2009 is an income of Rs. 60 lakhs including the difference in stock, contract receipts etc., and not additional income of Rs. 60 lakhs over and above the regular income as alleged by the AP – the addition sustained by the CIT(A) more or less is in conformity with the income of Rs. 60 lakhs promised to be offered by the assessee at the time of survey - the conclusion arrived at by the CIT(A) needs no interference – Decided against Assessee. Addition on account of contract receipts out of total addition – Held that:- The contention of the assessee that in sanitary contracts the labour component is major needs to be accepted as most of the time the customer himself purchases the sanitary items - the CIT(A) was not justified in making addition of Rs. 4 lakhs on account of investment in working capital – thus, the addition of Rs. 4 lakhs is set aside - the total income offered by the assessee at the time of survey at Rs. 60 lakhs also includes the additional income from difference in stock as well as contract receipt – Decided in favour of Assessee.
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