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2019 (1) TMI 940 - ITAT MUMBAIAddition made on account of difference in quantitative details - Revision u/s 263 - discrepancy in stock of Dettol soap fresh - AO explained the conversion factor as erroneously applied by assessee - difference in stock i.e., unaccounted purchased worked out to ₹ 1737.45 MT which remained unexplained - Held that:- It is clear that the assessee has applied the conversion factor of Dettol soap as is marketed in bars weighing 75 gms and 150 gms whereas Dettol liquid soap is marketed in 250 ml. bottles/dispensers. Similarly, Dettol anticipated liquid is marketed in 100 ml. and 500 ml bottles and Dettol Shaving creams in 70 gms tubes. The dispute is restricted to the conversion factor applicable in respect of Dettol soap fresh of 75 gms packing and assessee has file quantitative information in this regard and it proves that the assessee is following the system of computing the weight of its item by multiplying the total no. of boxes with an appropriate multiplier. Similarly, once the multiplier per box is arrived at, the same is applied to the total no. of boxes and the total volume soap cakes, sold in grams is arrived at. The assessee has made a mistake while preparing the quantitative information for the relevant assessment year, as the concerned official of the assessee instead of applying the weight of Dettol soap fresh cake as 75 gms, applied as 250 gms (this is actually Dettol liquid soap sold in 250 ml). Now, the assessee has filed the complete data as discussed above and Revenue / learned CIT DR, could not controvert the above discussed facts before us. Accordingly, we are of the view that the difference in stock to the extent of 1737.45 mt in the stock of Dettol is entirely due to above errors, which has been properly explained with the re-conciliations supported by the book entries. Hence, we find no difference in the stock as above explained. Hence, we delete the addition and allow this appeal of the assessee. - Decided in favour of assessee.
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