2014 (6) TMI 743

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.... 3. The facts as culled out from the material on record are as under. 4. Assessee is a company stated to be engaged in the business of manufacturing of aluminium coils, foils, sheets and trading of aluminium coils. Assessee filed its return of income for A.Y. 05-06 on 24.10.2005 declaring total income of Rs. 22,24,930/-. The assessment was initially framed under section 143(3) vide order dated 31.12.2007 and later on the case was re-opened and order was passed under section 143(3) read with Section 147 on 29.10.2009 determining revised total income at Rs. 28,23,270/-. The case was again re-opened by issuing notice under section 148 and thereafter the assessment was framed under section 143(3) read with 147 vide order dated 12.11.2010 a....

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....onsidered the findings of the A.O as well as the submission of the appellant. The assessee is following the exclusive method of Excise duty and the assessee had already submitted the reconciliation statement along with the Income Tax Return. The learned AR has also reproduced the relevant copy of the tax audit report filed by him and it is evident that the appellant has correctly reconciled the position of valuation of the stocks as per the inclusive method and exclusive method as contemplated under Section 145A of the Act. Again, I find considerable merit in the argument of the learned AR that the CENVAT credit receivable has already been credited to the raw material purchase account and thus to that extent the value of raw material purcha....