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2022 (7) TMI 437 - ITAT CHENNAIAdditions on recasted value of closing stock - CIT(A) allowing the claim of the assessee that it had correctly valued the closing stock - whether CIT(A) failed to appreciate that value determined by the AO in respect of value of closing stock was based on facts and as per accounting principles? - HELD THAT:- CIT(A) has deleted the addition on the basis that the same was considered in the re-casted profit and loss account of earlier assessment year i.e., AY 2011-12 and hence he deleted the addition. We find no infirmity in the order of CIT(A) but in case the addition is deleted in AY 2011-12 and that re-casted profit and loss on account of valuation of closing stock is made and that addition is deleted on same reasoning, that this year the issue has to be dealt with on merits. In view of the above, we remand this matter back to the file of the AO for verification whether this addition is already considered in AY 2011-12 while making addition by the AO at Rs. 16,52,72,766/-. In case that addition is deleted on merits, the AO will verify and accordingly decide the issue afresh after confronting to the assessee. This issue of the Revenue appeal is allowed for statistical purposes. Addition on notional interest on interest bearing funds advanced for non-business purposes interest free - assessee has not explained any commercial expediency for giving interest free loans - CIT-A deleted the addition - HELD THAT:- We noted that the Revenue now before us could not controvert the above facts situation that there are funds available with both interest free in making these interest bearing advances and few there are opening balance also. Once interest free funds available with the assessee, which is more than the interest free advances, no disallowance can be made by resorting the provision of section 36(1)(iii) of the Act. We noted no infirmity in the order of CIT(A) and hence this issue of Revenue appeal is dismissed. Validity of assessment as beyond the limitation period prescribed vide sec. 153 - HELD THAT:- We noted that the assessment order was framed vide order dated 31.03.2015 and passed within time limit i.e., 31.03.2015, but it was served on the assessee only on 13.04.2015. The limitation expires on 31.03.2015. The assessment order passed was within the limitation and accordingly, we dismiss this ground of appeal.
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