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2015 (9) TMI 17 - AT - Income TaxPenalty u/s 271(1)(c) - whether change of accounting system which resulted valuation of stock at a lower side do not show deliberate intention of the assessee of furnishing inaccurate particulars/ concealment of facts - CIT(A) deleted addition - Held that:- The assessee had submitted its explanation before the AO at the time of assessment proceedings as well as penalty proceedings. The assessee has changed the method of valuation of closing stock which will automatically be the opening stock of subsequent year. The assessee had duly disclosed complete particulars regarding change in the method of valuation of stock in process from cost plus expenses to estimated realizable value which was mentioned by the assessee in its annual report of the company and tax audit report that in the Modern Thread Unit, the valuation of stock in process had been changed from cost plus expenses to net realizable value. The valuation of work in process had been done as per AS-2 issued by Institute of Chartered Accountant of India. Further the company had been closed on 20-08-2001 and valuation of stock was done on 31-03-2002. Thus there was no production carried out by the company since 31-03-2002. The ld. DR could not controvert this findings of the ld. CIT(A). The cases relied on by the assessee are squarely applicable to the case of the assessee. Therefore, in view of the above facts and circumstances of the case, we confirm the order of the ld. CIT(A). - Decided against revenue.
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