2025 (4) TMI 2019

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....d by the assessee is directed against the order of the National Faceless Assessment Centre / Commissioner of Incometax (Appeals) ["CIT(A)" for short] dated 27.10.2022 for the assessment year 2017-2018. 2. There is a delay of 49 days in filing this appeal before the Tribunal. The appellant filed a condonation petition along with an Affidavit of the Managing Partner of the appellant firm, stating....

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....ncome of Rs. 17,08,290. While doing so, the AO made an addition to the closing stock of Rs. 5,92,030 by holding that the appellant has not valued the closing stock by including the VAT rate on the closing stock. 4. Being aggrieved, an appeal was filed before the CIT(A), who vide the impugned order confirmed the action of the AO for non-prosecution and on merits. 5. Being aggrieved, the appel....

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....d. While discussing this issue, the Privy Council opined as under:- "If the method of altering both valuations is not adopted it, is perfectly plain that the profit which is brought forward is not the real one. It may be more, or it may be less, but it has no relation to the true profit if the stock is valued on one basis when it goes out without considering the value of the stock when it....