Obsolete stock loss claims turn on factual proof; concurrent findings and distinguishable precedent sustained the disallowance.

Loss claimed on obsolete stock was disallowed because the assessment and appellate authorities had recorded concurrent factual findings that the laptops and motherboards had become obsolete, and no perversity was shown in those findings. The Bombay High Court treated the Revenue's cited precedent as distinguishable, since that case involved a claim of obsolescence without matching factual support. The assessee's consistent year-to-year accounting treatment also supported the claim under the applicable accounting framework, but it did not justify interference with the disallowance on the facts before the Court.

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Issues: Whether the disallowance of loss claimed on obsolete stock was liable to be interfered with, and whether the earlier decision cited by the Revenue controlled the present facts.

Analysis: The assessment and appellate records showed that the stock of laptops and motherboards was found to have become obsolete. The authorities below recorded concurrent findings of fact and there was no material to show perversity in those findings. The earlier decision relied upon by the Revenue was held to be distinguishable because it turned on different facts, including a claim of obsolescence without corresponding factual support. The assessee's consistent accounting treatment from year to year was also treated as supporting the claim under the applicable accounting framework.

Conclusion: The question was answered against the assessee and in favour of the Revenue; the disallowance did not warrant interference.

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