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TMI Blog2021 (8) TMI 1408X X X X Extracts X X X X X X X X Extracts X X X X ..... Mr. Vishal Kalra and Mr. S.S. Tomar, Advocates Respondents Through: Mr. Ruchir Bhatia, Sr. Standing Counsel. JUDGMENT MANMOHAN, J: (Oral) 1. The petition has been heard by way of video conferencing. 2. Present writ petition has been filed challenging the order dated 28th April, 2021 [received vide email on 18th June, 2021] passed by respondent no. 2, Income Tax Officer (TDS), Circle 73(1), un ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... does not claim deduction in the computation of taxable income, forming part of the return of income. He emphasises that the treatment for slow and ageing inventory is revenue neutral and the same has been done in accordance with the Accounting Standard 2 stipulated by the Institute of Chartered Accountants of India. 5. According to him, this provision for slow and ageing inventory gets reve ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... aid down by the Central Board of Direct Taxes vide Notification 8/2018 as well as the Rule 28AA of the IT Rules which lay down the procedures and parameters for issuing certificates under Section 197 of the Act. He submits that the scope of scrutiny under Section 197 read with Rule 28AA is limited and as the AO had neither followed the procedure prescribed therein, nor given any reasons in the imp ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tax certificate. He also states that as there was limited scrutiny for A/Y 2018-19, the provision for slow and ageing inventory was not examined by the AO. 13. Mr. Bhatia, however, states that as now in the writ petition the petitioner has clarified that the provision creating slow and ageing inventory in relation to the relevant AY has not been claimed as a deduction in the said year, the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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