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2018 (12) TMI 1249 - AT - Income TaxUnaccounted stock difference and non revaluation of the value of stock - LIFO v/s FIFO method - Held that:- So far the method of valuation of closing stock is concerned, the assessee has been following the norm to compute the value of closing stock at cost and net reliable value whichever is lower by applying the LIFO method - quantitative analysis which has been prepared by the Registered Valuer at the time of survey and what is recorded in the stock register has no difference except for 215 gms which is due to mis-weighing of items. We note that the valuation of stock made by the assessee was well-established and was consistently being followed by the assessee in the earlier years. Once adopted method of valuing closing stock should be followed consistently unless there is cogent reason to change it. It is a well settled legal position that factual matters which permeate through more than one assessment year, if the Revenue has accepted a particular's view or proposition in the past, it is not open for the Revenue to take a entirely contrary or different stand in a later year on the same issue, involving identical facts unless and until a cogent case is made out by the Assessing Officer on the basis of change in facts. For that we rely on the order of the Hon’ble Supreme Court in RadhaSoamiSatsang vs. CIT [1991 (11) TMI 2 - SUPREME COURT]. - Decided against revenue
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