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2014 (12) TMI 1017 - ITAT AHMEDABADValuation of WIP - WIP was value of actual sales of moulds and not the cost of moulds or not - Restriction of addition of ₹ 20,97,008/- to R.4,14,403/- on unaccounted sales Facts and material properly appreciated or not Held that:- CIT(A) rightly was of the view that the value of the mould could have been taken at Nil - these moulds have not been accounted for in stock - There is no reason to assume that the mould had been valued at Nil - these mould have also not been accounted for in the books of accounts of the appellant - the appellant has not accounted for these moulds in the books of accounts - no material could be produced to show that ₹ 45,06,566/- mentioned in the WIP was value of actual sales of moulds and not the cost of moulds which was transferred from WIP Decided against revenue. The assessee stated that the moulds of ₹ 4,14,403/- was defective and had no realizable value - the CIT(A) has held that the auditor of the assessee has denied to have received any information about moulds having Nil value - the CIT(A) opined that there is no plausible reason to value the moulds at Nil and the quantity of these moulds were not accounted for in the books of account - there is no plausible reasons for valuing these moulds at Nil - Since these moulds are also not accounted for in stock it stands to reason that these moulds have been sold outside books of accounts - the addition made by the AO on account of unaccounted sales is reduced from ₹ 20,97,008/- to ₹ 4,14,403/- revenue could not point out any specific mistake in the findings of the CIT(A) - No material has been brought to show that any error in the findings of the CIT(A) and to show that the moulds of ₹ 4,14,403/- were defective and their realizable value was Nil thus, the order of the CIT(A) is upheld Decided against assessee.
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