Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Undervaluation of closing stock was addressed by accepting contemporaneous excise records and purchase ledgers as displacing the Assessing Officer's arithmetic shortfall, the typographical repetition in Form 3CD being found non-determinative; consequence: quantity-based addition deleted. Valuation was held consistent with the accounting principle of lower of cost or net realisable value where the assessee proved stock damage from heavy rains, and the reduced market valuation was accepted; consequence: value-based addition deleted. The AO's separate addition for 'variation in stock' after valuing closing stock was treated as impermissible double addition and deleted; Revenue's appeal dismissed.
Undervaluation of closing stock was addressed by accepting contemporaneous excise records and purchase ledgers as displacing the Assessing Officer's arithmetic shortfall, the typographical repetition in Form 3CD being found non-determinative; consequence: quantity-based addition deleted. Valuation was held consistent with the accounting principle of lower of cost or net realisable value where the assessee proved stock damage from heavy rains, and the reduced market valuation was accepted; consequence: value-based addition deleted. The AO's separate addition for 'variation in stock' after valuing closing stock was treated as impermissible double addition and deleted; Revenue's appeal dismissed.
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