2020 (12) TMI 567

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....t : Mr.R.Vijayaraghavan for Mr.Venkata Narayanan for M/s Subbaraya Aiyar Padmanaban For Respondent : Mr.M.Swaminathan Senior Standing Counsel Mr.V.Pushpa Junior Standing Counsel JUDGMENT [Judgment of the Court was delivered by T.S.SIVAGNANAM, J.] This appeal, at the instance of the assessee filed under Section 260A of the Income Tax Act, 1961 (the 'Act' for brevity), is directe....

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....laring the same income. The case was selected for scrutiny and notice under Section 143(2) of the Act was issued on 19.08.2013. Subsequently, notice under Section 142(1) of the Act was issued along with questionnaire. The assessee produced the details called for pursuant to such notice. The business of assessee's firm was taken over by a private limited company on 08.01.2012 together with all ....

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....y the Department in the earlier years and additions were made to the extent of closing stock. Accordingly, the assessing officer held that the closing stamp has been under valued by Rs. 2,51,214/- and this was added to the total income. 5. The assessee aggrieved by such order, preferred an appeal before the Commissioner of Income Tax, [Appeals] 18, [for brevity 'CITA'] Chennai, who by o....

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....iod was restricted from 01.04.2011 to 07.01.2012. Before us the endevaour of the assessee is to convince us that the valuation of the closing stock would arise only when the stock continues to be held by the assessee in the next year and not in a case where the business of the assessee along with the stock was taken over by the company on 08.01.2012. 8. It is the further submission that what wa....