2008 (4) TMI 186

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....the Tribunal, the Revenue has filed the present appeal. 3. Brief facts leading to the dispute are that the assessee is a registered firm showing income from business of manufacturing rubber flaps and retreading of tyres. Return was filed by the assessee declaring loss at Rs. 86,170 on October 29, 2001. During the assessment proceedings, the Assessing Officer noted that the assessee had hypothecated its stock with Bank of India, Hauz Khas, New Delhi for availing of overdraft facility. The details of stock hypothecated with the bank quantity-wise and value-wise was obtained from the bank, according to which the total value of stock was Rs. 33,98,640 whereas the assessee had declared the valuation of closing stock at Rs. 16,14,155 in its bo....

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....hat, if an addition to be made on account of difference between the stock shown to the bank and the stock shown in the balance-sheet is to be confirmed, reduction should be allowed for the difference which was there in the opening stock. Thus, it was pointed out that net difference of Rs. 2,35,983 only (Rs. 17,84,486 to Rs. 15,48,502) would be left which could be added as against the addition of Rs. 17,84,486. 7. The Commissioner of Income-tax (Appeals) confirmed the addition in the difference of stock as made by the Assessing Officer (which has also been accepted by the assessee), though he allowed the relief of Rs. 15,48,502 to the assessee, accepting alternate plea of the assessee that such difference in the valuation of closing stock....