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TMI Blog2015 (10) TMI 1872X X X X Extracts X X X X X X X X Extracts X X X X ..... appeal by the Revenue is directed against the order passed by the ld. CIT(A) on 10.05.2012 in relation to the assessment year 2003-04. 2. The Revenue has filed revised grounds of appeal. A common issue raised through both the effective grounds is against the allowing of claim of the assessee of Rs. 33,91,077/- as the part value of the opening stock of finished goods on 1.04.2002. 3. It is the s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... count. In that way, the assessee did not claim any deduction for the amount debited in the P&L Appropriation account in the computation of its total income. During the course of the assessment proceedings, it was contended that the remaining part of the value of the opening stock of finished goods at Rs. 33,91,077/-should also be allowed as deduction by enhancing the figure of Opening stock to its ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... considering the assessee's claim afresh as per law giving due opportunity to the assessee. 5. In the second round of proceedings, the AO again followed his earlier view and did not allow deduction for the differential amount of the value of the opening stock of finished goods. The ld. CIT(A) accepted the assessee's claim, against which the Revenue has come up in appeal before us. 6. We have hear ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d by considering the change in the method of valuation of closing stock of finished goods from this year onwards from the earlier year's sale price less 10% to the current year's sale price less 40%. The differential amount of Rs. 33.91 lac is nothing but the difference of 30% due to the change in the method of valuation of opening stock of finished goods. This differential amount of Rs. 33.91 lac ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ccounting treatment cannot impact the calculation of correct total income. In our considered opinion the ld. CIT(A) was justified in enhancing the value of opening stock of finished goods with Rs. 33.91 lac and thereby reducing the total income to this extent. We therefore, countenance the view taken by the ld. CIT(A) on this issue. 8. In the result, the Revenue appeal is dismissed. Order pronou ..... X X X X Extracts X X X X X X X X Extracts X X X X
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