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Closing-stock valuation based on net realisable value requires supporting material establishing the basis of that value. The High Court found that the assessee had not substantiated its claimed net realisable value, while the Assessing Officer adopted a realisable or market value below cost. The principle of consistency did not apply because there was no change in the valuation method. The appellate authorities' findings on the applicable valuation rate were concurrent findings of fact, raising no substantial question of law. The addition for undervaluation of closing stock was therefore sustained and the tax appeal was dismissed.
Closing-stock valuation based on net realisable value requires supporting material establishing the basis of that value. The High Court found that the assessee had not substantiated its claimed net realisable value, while the Assessing Officer adopted a realisable or market value below cost. The principle of consistency did not apply because there was no change in the valuation method. The appellate authorities' findings on the applicable valuation rate were concurrent findings of fact, raising no substantial question of law. The addition for undervaluation of closing stock was therefore sustained and the tax appeal was dismissed.
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