9911796707
TMI Blog2022 (5) TMI 1623X X X X Extracts X X X X X X X X Extracts X X X X ..... ssee has not submitted any supporting evidences regarding its practice of valuation of closing stock though assessee has already submitted the evidences of stock valuation. 2. The learned commissioner (Appeal) erred in stating that assessee has failed to submit trial Balance and Profit and loss account as on date of survey during the Assessment proceeding. 3. Your appellant prays for appropriate relief on above grounds of appeal" 3. The assessee is engaged in the business of trading of gold and silver ornaments. The case was selected for scrutiny on the basis of the CBDT's guidelines wherein survey proceedings under Section 133A of the Income Tax Act, 1961 had been carried out at the business premises of the assessee during the rele ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ale Closing stock Opening stock on date of survey i.e. 12/12/2014 8127.28 Stock declared in survey 12,996.72 21,124.00 Transaction made from 12/12/2014 to 31/12/2014 0 44.56 21079.44 Transaction from 01/01/2015 to 31/03/2015 0 508.64 20615.36 6. As on 31.03.2015 the assessee has valued the stock of gold at the rate of Rs.2683.44 per gram at cost price by following the LIFO method. The value of stock as on 31.03.2015 is Rs.1,76,93,659/- which was valued at cost of Rs.2683.44 per gram by following LIFO method. Due to the decrease in market rate of gold as on date of survey compared to rate on date of 31.03.2015, there is reduction in value of stock by Rs.1,29,133/- ( i.e. 2773.478 gram x (Rs.2730 per gra ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... .e. 2015-16:- Item Stock declared on 12/12/2014 Value of Stock as on 12/12/2014 Value of Stock as on 31/03/2015 Difference in value of stock Gold Ornament 2773.478 grams 7571595 7442462 129133 Silver Ornaments 12996.72 grams 474380 422041.7 52338.3 Total 181471.3 7. The Ld. A.R. further submitted that the assessee has already declared gold and silver ornaments in survey proceeding in its return of income. Thus, the assessee never failed to disclose Rs.13,57,856/- and the addition may be deleted. 8. The Ld. D.R. submitted that the Assessing Officer has rightly made the addition as there was clear difference related to opening stock and closing stock of gold and silver. The partner of the assessee-fi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the return of income filed by the assessee. Merely, offering the declared gold and silver ornaments in survey proceedings in subsequent A.Ys. cannot held that there was no excess stock/unaccounted stock available during the A.Y. 2015-16. The documents shown at the time of hearing on 11.04.2022 by the assessee has not given the bifurcation as to how much was the quantity sold on the particular period related to gold ornaments and silver ornaments which shows that the assessee was deliberately following unaccounted stock and when survey conducted the same was admitted by the assessee. There is finding of the Assessing Officer that the G.P. shown during the survey period is higher than the post-survey period and the Assessing Officer also poin ..... X X X X Extracts X X X X X X X X Extracts X X X X
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