Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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Addition for revaluation of closing stock was contested on the ground that the assessee had previously provided for diminution in value of old/damaged stock and revalued closing stock for the year with a quantified reduction of Rs. 26,88,599, not the higher figure estimated by the AO; the Tribunal accepted the lower figure. The Tribunal found the valuation procedure-branch head physical verification, Director of Societies supervision, auditor approval-scientific and reasonable and, since audited books were not rejected under Section 145(3), held the AO's addition on stock valuation unjustified.
Addition for revaluation of closing stock was contested on the ground that the assessee had previously provided for diminution in value of old/damaged stock and revalued closing stock for the year with a quantified reduction of Rs. 26,88,599, not the higher figure estimated by the AO; the Tribunal accepted the lower figure. The Tribunal found the valuation procedure-branch head physical verification, Director of Societies supervision, auditor approval-scientific and reasonable and, since audited books were not rejected under Section 145(3), held the AO's addition on stock valuation unjustified.
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