2011 (11) TMI 693 - AT - Income Tax

Tribunal affirms CIT(A)'s decision on stock valuation method, rejects Revenue's appeal

The Tribunal upheld the CIT(A)'s decision, dismissing the Revenue's appeal and affirming the deletion of the Rs. 53,13,006/- addition to the assessee's ... Incorrect valuation of stock - Held that:- Revenue Department not only in past but in subsequent years also accepted the claim of the assessee. This stand of the AO would demolish all arguments of the learned DR. The findings of the learned CIT(A) on correct method of valuation adopted by the assessee have not been rebutted through any evidence on record. The learned CIT(A) on proper appreciation of the facts and material on record rightly followed the various orders of the Tribunal including the orders of jurisdictional ITAT Ahmedabad Bench in arriving at the just decision in the matter. We, therefore, do not find any justification to interfere with the order of the learned CIT(A). Considering the above discussion, we do not find any merit in the appeal of the revenue. Issues Involved:1. Incorrect valuation of stock by the assessee.2. Consistency in the method of stock valuation.3. Applicability of Accounting Standards.Detailed Analysis:1. Incorrect Valuation of Stock by the Assessee:The primary issue in this appeal was the method of valuation of closing stock adopted by the assessee, which was disputed by the Assessing Officer (AO). The AO argued that the assessee's method of valuing the closing stock based on the average market price of the last three years was incorrect and did not conform to the recognized commercial accounting policy, which mandates valuation at the lower of cost or market price. The AO revalued the closing stock at cost or market price as of 31-03-2006, resulting in an addition of Rs. 53,13,006/- to the assessee's income.2. Consistency in the Method of Stock Valuation:The assessee contended that it had consistently followed the method of valuing the inventory at the weighted average cost for several years, and this method had been accepted by the Revenue in previous assessments, including the scrutiny assessment for the assessment year 2005-06. The assessee argued that the principle of consistency should apply, and the AO should not have disturbed the accepted method of valuation. The CIT(A) agreed with the assessee, emphasizing the importance of consistency and noting that the AO had accepted the same method in earlier and subsequent years.3. Applicability of Accounting Standards:The CIT(A) and the Tribunal examined the applicability of Accounting Standard 2 (Revised) issued by the Institute of Chartered Accountants of India. The CIT(A) concluded that the assessee's method of valuing the inventory at the weighted average cost was in line with AS-2 (Revised) and was a generally accepted accounting method in the jewelry business. The CIT(A) also noted that the AO had incorrectly applied Paragraph 14 of AS-2, which deals with specific identification of costs, whereas the assessee's case was covered under Paragraph 16, which allows for the weighted average cost formula.Tribunal's Findings:The Tribunal upheld the CIT(A)'s decision, emphasizing the principle of consistency and the fact that the Revenue had accepted the same method of valuation in earlier and subsequent years. The Tribunal also noted that the AO had not provided any evidence to rebut the CIT(A)'s findings on the correct method of valuation adopted by the assessee. The Tribunal dismissed the departmental appeal, affirming that the assessee's method of valuing the closing stock was appropriate and consistent with accepted accounting standards.Conclusion:The appeal by the Revenue was dismissed, and the CIT(A)'s order deleting the addition of Rs. 53,13,006/- was upheld. The Tribunal emphasized the importance of consistency in the method of stock valuation and the adherence to recognized accounting standards. The decision reinforced that the AO should not arbitrarily change the accepted method of valuation without substantial justification.