Dismissing the appeal the Court held that   all the Income-tax authorities based on the material before them, or the lack of proper evidence before them, held that the disparity between the cost price and the market price remained unexplained by the assessee. The Tribunal noted that the assessee failed to explain the basis for valuation of the closing stock being lower than even the average cost or the average market price. The Tribunal also noted that the assessee failed to produce any cogent evidence to substantiate its claim even before the Tribunal itself despite the grant of opportunity. The valuation adopted by the Revenue was valid. No question of law arose from the order. .  Followed CIT v. British Paints  India Ltd  ( 1991) 188 ITR 44 (SC)  ( AY.  2009-10)