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2015 (10) TMI 1872

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..... ppropriation account is an erroneous approach of showing the value of opening stock, which amount should have been in fact, considered in entirety in the trading account, but such an erroneous accounting 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 ₹ 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. - Decided against revenue. - I.T.A .No.4305/Del/2012 - - - Dated:- 8-7-2015 - SHRI R. S. SYAL AND SHRI A. T. VARKEY, JJ. For The Revenue : Sh. P. Dankanunjna , Sr. DR For The Assessee : Sh. Ravinder Aggar .....

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..... oceedings, it was contended that the remaining part of the value of the opening stock of finished goods at ₹ 33,91,077/-should also be allowed as deduction by enhancing the figure of Opening stock to its full value in its Trading account. The Assessing Officer came to hold that such a claim could be entertained only by means of revised returned and in the absence of the assessee having furnished a revised return, this claim was not acceptable. 4. The assessee carried the matter in appeal before the ld. CIT(A), who relying on the judgment of Hon ble Supreme Court in the case of Goetze (India) Ltd. vs. CIT 284 ITR 323 (SC), upheld the assessment order denying the assessee s claim for increasing the value of opening stock of finished .....

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..... g 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 ₹ 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 ₹ 33.91 lac was debited to the P L appreciation account, but not claimed as deduction in the computation of total income. 7. The figure of the value of the opening stock of finished goods of last year is not disputed. There can be no dispute on the proposition that the value of closing stock of preceding year constitutes value of opening stock of the current ye .....

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