Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
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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