TMI Blog2018 (2) TMI 1698X X X X Extracts X X X X X X X X Extracts X X X X ..... has already concluded in his operative part that the preceding round of assessment had already dealt with this survey statement aspect. We therefore see no reason to interfere with the CIT(A)’s findings extracted hereinabove deleting the impugned addition. - Decided in favour of assessee - ITA No. 2259/Ahd/2014 - - - Dated:- 19-2-2018 - SHRI PRAMOD KUMAR, ACCOUNTANT MEMBER AND SHRI S. S. GODARA, JUDICIAL MEMBER For The Revenue : Shri V. K. Singh, Sr. D.R. For The Assessee : Shri P. M. Mehta Shri G. M. Thakor ORDER PER S. S. GODARA, JUDICIAL MEMBER This assessee s appeal for assessment year 2008-09 arises against the CIT(A)-XI, Ahmedabad s order dated 15.05.2014, in case no. CIT(A)-XI/13/ACIT, Cir-6/13-14, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... strictly in accordance with the Accounting Standard (AS-2) prescribed by the Institute of Chartered Accountants of India and gives the exact and precise value of closing stock leading to determination of correct profit. It has been submitted by the appellant that the finished goods were valued after considering the quantity of raw material consumed for a specific product, the cost of purchase inclusive of all taxes and duties is also applied to the basic raw material quantity which is consumed in the production and there after the over head cost, pecking cost, pecking cost, other direct expenses as well as excise duty are also allocated to arrive at the correct cost of finishing goods. It has also been submitted by the appellant that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vation of the AO that it had made a disclosure in survey which has not been accounted for, it is noted that the appellant has separately accounted for the disclosures made during the course of survey in different items such as unaccounted expenses towards construction, unaccounted cash, unaccounted receivables, unaccounted expenses towards gifts articles, unaccounted sales packing material, unaccounted wages and difference in valuation of raw material and packing materials. Therefore, it would be incorrect to say that the appellant has not honoured the disclosure made during the course of survey. This issue has already been considered in the earlier round of assessment. The only issue which is now to be decided is whether the change of meth ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... has explained that the overhead expenses are equally apportioned among the quantity of tablets manufactured. Accordingly all the overhead expenses are calculated on the basis of the number of tablets manufactured and is accordingly allocated to the type of medicine manufactured in proportion to the number of tablets manufactured. It was however, noted that the Accounting Standard-2 prescribes that all over at cost including the depreciation should also be apportioned to the valuation of closing stock, but the same was not done by the appellant while valuing the stock. The appellant has submitted that if the allocation of depreciation is also taking into account a further increase of ₹ 1,98,230/- shall have to be made in the value of c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essee has earlier filed ITA No. 216/Ahd/2012 against the CIT s Section 263 order dated 19.12.2009 (supra). Learned co-ordinate bench s order upholding the CIT s revision directions in principle comprise pages 45 to 48 of the paper book. There is no dispute that the assessee s Auditor had made special note in its audit report form 3CD stating it to have been valuing closing stock of finished goods at cost thereby reducing profit and margin from sale price in arriving at the relevant costs figures. He then clarified that all this was stated to have resulted in the impugned difference in stock valuation of ₹ 59,91,122/- having necessary bearing of the profits have been increased for this amount. It also read that opening stock valuation ..... X X X X Extracts X X X X X X X X Extracts X X X X
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