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2012 (11) TMI 95 - AT - Income TaxExpenditure on Research and Development - Capital or revenue in nature alleged that since the assessee had already sold these products, therefore, the technology was with the assessee Held that:- Research is a continuous process. Even if the assessee had developed some protype Pin Double Decker they may still require further improvements. Mere selling of protype of production would not show that the assessee already had the technology of the same production - in favour of the assessee Valuation of closing stock alleged that valuation given to the bank was higher Held that:- stock was not pledged with the bank and it was only hypothecated - it was a case of hypothecation of stock. Therefore, there can be difference in valuation - valuation given to the bankers has no co-relation with the actual value to be adopted for the balance sheet purposes. Bankers are generally given the market value of stock whereas the actual value is shown at the lower of cost or net realizable value in the accounts - in favour of assessee
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