TaxTMI 
TaxTMI 
2016 (3) TMI 1293
X X X X Extracts X X X X
X X X X Extracts X X X X
....ess of execution of contracts mainly in Civil , Mechanical and Trunkey Jobs in India and abroad. I t is also engaged in the business of structural and equipment erection works and manufacturing of Railway wagons, freight containers, bunk house, bai ley bridge, etc. The return of income for the year under consideration was f i led by it on 28.09.2010 declaring total income of Rs. 66,23,21,180/-. In the assessment completed under section 143(3) vide an order dated 21.03.2013, the total income of the assessee was determined by the Assessing Officer at Rs. 74,11,91,710/- after making certain additions. The records of the said assessment came to be examined by the ld. CIT and on such examination, he found that the assessee-company had valued the....
X X X X Extracts X X X X
X X X X Extracts X X X X
....s not found acceptable by the ld CIT and he proceeded to set aside the order passed by the Assessing Officer under section 143(3) by exercising the powers conferred upon him under sect ion 263 with a direction to the Assessing Officer to pass a fresh order after examining the issue of valuation of closing stock of Tools and Tackles. Aggrieved by the order of the ld. CIT passed under section 263, the assessee has preferred this appeal before the Tribunal . 3. The ld. counsel for the assessee submitted that the method of valuation of closing stock of Tools and Tackles by writing off 20% of the weighted average cost was consistently followed by the assessee company and the same was al l along accepted by the Assessing Officer in the earlier y....
X X X X Extracts X X X X
X X X X Extracts X X X X
....nditure" . As is clearly evident from the written submissions filed by the assessee during the course of assessment proceedings, the basis of valuation of Tools and Tackles was explained by the assessee in reply to the query raised by the Assessing Officer during the course of assessment proceedings and it was also specifically brought to the notice of the Assessing Officer by the assessee that the same basis was consistently followed even in the earlier years, which had already been accepted. I t is thus clear that a query on the issue of valuation of closing stock of Tools and Tackles was specifically raised by the assessee during the course of assessment proceedings and after having satisfied with the explanation offered by the assessee....