DCIT v. Amrit Banaspati Company Ltd. (2023) 203 ITD 230 /226 TTJ 137 (Delhi) (Trib.)

S. 145 : Method of accounting-Undervaluation of stock-Fall in GP-Allegations made by Special Auditor-Rejection of books of account is unjustified.

Assessing Officer on basis of allegations alleged by Special Auditor that there was fall in GP rate for relevant year by below 0.44 per cent as compared to immediately preceding assessment year rejected books of account of assessee and alleged that assessee had undervalued closing stock of salt and rice. Tribunal held that  there was error in Special Auditor’s report as there was only a marginal fall of 0.27 per cent as against 0.44 per cent indicated by Special Auditor.  Further, on perusal of details it was found that assessee had maintained proper books of account. Month-wise details of purchases and sales were provided by assessee along with valuation of closing stock.  Assessing Officer rejected books of account only on basis of allegations alleged by Special Auditor.Since complete details of valuation of closing stock were furnished and such data was also prepared from exhaustive accounting of assessee, observations of Assessing Officer were very general in nature and were purely based on assumptions and surmises without bringing any comparable case on record. Therefore, Assessing Officer is  not justified in rejecting books of account of assessee. (AY. 2007-08)