The Tribunal held that the entire exercise of adopting the average rate as on the date of survey was purely ad hoc. The adjustment made to the valuation of these goods to the extent of three per cent and eight per cent was too minor to hold that the assessee had attempted any undervaluation of stock. The addition made on account of undervaluation of stock of raw material and finished goods was to be deleted. (AY. 2013-14)
Chirai Salt (India) Pvt. Ltd v. Dy. CIT (2022)97 ITR 12 (SN) (Ahd) (Trib)
S. 145A : Method of accounting-Valuation-Under valuation of stock-Value of opening stock lower than admitted during survey-Value of opening stock of finished goods higher than average rate-Entire exercise of valuation adhoc and without any basis-Adjustment too minor to hold assessee attempted undervaluation of stock-Additions not justified.[S.133A]