2020 (4) TMI 404

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.... in deleting the addition of Rs. 3,74,11,219/- on account of difference in trading account ignoring the fact that the assessee has failed to reflect correct income as per memorandum of trading account as per provisions of section 145A of the IT Act, 1961. 2. Whether on the facts and circumstances of the case, the learned CIT(A) is correct in excluding the duty/cess/fees in the memorandum trading account ignoring the provisions of section 145A of the I.T. Act, 1961. 3. The appellant craves leave, to add, alter or amend any ground of appeal raised above at the time of the hearing. 2. Briefly stated facts of the case are that the assessee was engaged in the business of manufacturing and sale of radiators, in cooling modules and interco....

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....on record. The issue in dispute involved in the case is whether there any difference in valuation of the stock as compared to exclusive method, if inclusive method is adopted for valuation of the stock. The Ld. CIT(A) has adjudicated the issue in dispute and deleted the addition of Rs. 3,74,11,219/-. The relevant finding of the Ld. CIT(A) is reproduced as under: "5.5 Coming to the ground at (c) above with respect to the disallowance on account of the difference in trading account u/s 145A in the impugned order, it is observed there from that it is mentioned, inter alia, "...The assessee has failed to reflect income as per memorandum of trading account as above. The plea of the assessee that duty expenses were utilized cannot be accepted b....

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....tween the trading account computed under the exclusive method wherein duty is not included in the value of an expenditure or inventory or sale or closing stock and under the inclusive method duty is included; the sanctity of the account will remain only if under both methods, the results (profits) are same. 5.6 From the submission of the AR of the appellant it is observed that in the calculation mentioned in the impugned order, arithmetical errors have crept in inadvertently whereby the difference in profit has arisen in the trading accounts between both methods. Also, other mistakes pointed out during the appeal hearing appear plausible as these do appear in the calculations contained in the impugned order - * Totaling error - total ....