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2019 (11) TMI 1700 - ITAT CUTTACKRevision u/s 263 by CIT - Addition of Notional Provision of Excise duty on Closing Stock of Finished goods (which is not the actual liability arised as on 31.03.2014) - HELD THAT:- We observe from the trading profit and loss account submitted by the assessee, he has made provision on excise duty from the closing stock of finished goods and showing it as a liability in the balance sheet. From the statements of the assessee that there is no effect in the profit and loss account, it is notable that if there is no effect in the profit and loss account after making provisions and showing as liability in the balance sheet then why the assessee is making provisions in his profit and loss account. The reason for making provision could not be explained by the assessee. In this regard, he just submitted that the provisions have been made at the end of the year and it is reversed in the opening of next financial year. While going through the assessment order passed by the AO, the AO has not examined this issue as to what for the reason for making provisions and showing it as a liability and reversed it into the opening of the next financial year. This issue should have examined by the AO, however, he did not do so. After considering the totality of facts and circumstances of the case, the ld.Pr. CIT has rightly invoked his revisonary powers u/s.263 of the Act. Accordingly, we do not see any good reason to interfere with the findings recorded by the Pr. CIT in directing the AO to modify the scrutiny assessment order by disallowing sum which had been debited towards “provision of excise duty on closing stock of finished goods” u/s.43B - Decided against assessee.
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