2022 (5) TMI 1623

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....k of Rs.13,57,865/- on invalid ground that Assessee has not submitted any supporting evidences regarding its practice of valuation of closing stock though assessee has already submitted the evidences of stock valuation. 2. The learned commissioner (Appeal) erred in stating that assessee has failed to submit trial Balance and Profit and loss account as on date of survey during the Assessment proceeding. 3. Your appellant prays for appropriate relief on above grounds of appeal" 3. The assessee is engaged in the business of trading of gold and silver ornaments. The case was selected for scrutiny on the basis of the CBDT's guidelines wherein survey proceedings under Section 133A of the Income Tax Act, 1961 had been carried ....

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....1/01/2015 to 31/03/2015 670.28 2310.80 6593.65 Silver Ornaments (In Gram) Particulars Purchase Sale Closing stock Opening stock on date of survey i.e. 12/12/2014     8127.28 Stock declared in survey 12,996.72   21,124.00 Transaction made from 12/12/2014 to 31/12/2014 0 44.56 21079.44 Transaction from 01/01/2015 to 31/03/2015 0 508.64 20615.36 6. As on 31.03.2015 the assessee has valued the stock of gold at the rate of Rs.2683.44 per gram at cost price by following the LIFO method. The value of stock as on 31.03.2015 is Rs.1,76,93,659/- which was valued at cost of Rs.2683.44 per gram by following LIFO method. Due to the decrease in market rate ....

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.... due to the difference in rate of gold and silver compared to 12.12.2014 to 31.03.2015 the following was impact on profit by Rs.1,81,471.3 in the concerned A.Y. i.e. 2015-16:- Item Stock declared on 12/12/2014 Value of Stock as on 12/12/2014 Value of Stock as on 31/03/2015 Difference in value of stock Gold Ornament 2773.478 grams 7571595 7442462 129133 Silver Ornaments 12996.72 grams 474380 422041.7 52338.3 Total       181471.3 7. The Ld. A.R. further submitted that the assessee has already declared gold and silver ornaments in survey proceeding in its return of income. Thus, the assessee never failed to disclose Rs.13,57,856/- and the addition may be deleted. ....