Section 263 Review: Closing Stock Valuation and Tax Neutrality Over Time Analyzed; No Revenue Prejudice Found.

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....Revision u/s 263 - valuation of closing stock, non increasing of closing stock by proportionate other direct expenses - The alleged under valuation of closing stock is a tax neutral exercise when seen over a longer horizon and thus, in effect, not prejudicial to the interest of the Revenue per se. Section 263 of the Act calls for existence of both the pre-requisites, namely; (i) order under revision should be erroneous as well as (ii) prejudicial to the interest of the Revenue. - AT....