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The High Court examined the method of valuation of stock and the application of the principle of consistency and regularity. It held that while the principle of consistency remains the same across assessment years, the valuation may change due to fluctuations in market prices and sale prices. The court agreed with the Assessing Officer's view that the average market price could not be used by the assessee because sale prices vary yearly. Regarding the decision in CIT vs. British Paints India Ltd, the court clarified that it was based on specific facts and cannot be treated as a binding precedent in all cases where sale prices change annually. The court ruled in favor of the revenue on both issues related to the method of stock valuation.
The High Court examined the method of valuation of stock and the application of the principle of consistency and regularity. It held that while the principle of consistency remains the same across assessment years, the valuation may change due to fluctuations in market prices and sale prices. The court agreed with the Assessing Officer's view that the average market price could not be used by the assessee because sale prices vary yearly. Regarding the decision in CIT vs. British Paints India Ltd, the court clarified that it was based on specific facts and cannot be treated as a binding precedent in all cases where sale prices change annually. The court ruled in favor of the revenue on both issues related to the method of stock valuation.
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