TaxTMI 
TaxTMI 
2015 (9) TMI 1284
X X X X Extracts X X X X
X X X X Extracts X X X X
....documentary evidence. The value of closing stock was on the same basis as consistently followed in all the preceding assessment years. No defect or any error in the method count existed nor found and detected. The G.P. Rate as declared was also undisputed. The correctness of the declared profit as reflected in the Trading account was well proved and substantiated by the method of accounting regularly employed was not disputed. Thus on facts and in law there was no warrant and legal justification for rejection of declared valuation of closing stock. b) That the Authorities below on facts and in law went wrong to reject the declared version and to make the addition of Rs. 2,11,326/-. The addition being erroneous, illegal and untenabl....
X X X X Extracts X X X X
X X X X Extracts X X X X
....e under section 143(2) dated 12/10/07 and 142(1) of the I.T. Act alongwith questionnaire dated 02/06/08 were issued to the assessee. In compliance to these notices, authorized representative of the assessee Sh. M.M. Chhabra, Advocate appeared from time to time and filed details and the case was discussed with him. Books of accounts consisting of computerized cash book, ledger, purchase and sale bills and some expenses bills /vouchers were produced which have been examined on test check basis. Thereafter, the AO concluded that the value of closing stock is taken as Rs. 35,67,641/- as against Rs. 33,56,315/- declared by the assessee and made addition of Rs. 2,11,326/- in the trading. And AO observed that the assessee has also debited expenses....
X X X X Extracts X X X X
X X X X Extracts X X X X
....rs of the revenue authorities. With regard to ground no.1 (a) & (b) are concerned, I find considerable cogency in the assessee's contention mentioned in the Ld. CIT(A) order that all the purchases and direct expenses under different heads and also sales were verifiable and supported by documentary evidence. The value of closing stock was on the same basis as consistently followed in all the preceding assessment years. No defect or any error in the method count existed nor found and detected. The G.P. Rate as declared was also undisputed. The correctness of the declared profit as reflected in the Trading account was well proved and substantiated by the method of accounting regularly employed was not disputed. Thus on facts and in law the....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... rejected the LIFO method as applied by the assessee. I further find that the Hon'ble Apex court in the case of Commissioner of Income-tax v. Woodward Governor India P. Ltd. [2009] 312 ITR 254 (SC) has held that "Method of accounting followed by assessee continuously, binding on AO unless he find that the system followed does not reflect true profit." Keeping in view of the facts and circumstances of the case and respectfully following the precedents as aforesaid, I delete the addition made by the AO and confirmed by the Ld. CIT(A) and allow the ground no. 1 (a) & (b) raised by the assessee. 7. With regard to ground no. 2(a) & 2(b) & 3(a) 3(b) are concerned, I find that the expenditure on job work was genuinely incurred in the ....