HCC Samsung Joint Venture v. ACIT (2022) 220 DTR 105 / 220 TTJ 671 (Mum)(Trib)

S. 145 : Method of accounting-Work in progress-Notional valuation-Consolidating books of account-Addition is deleted.[S. 69]

Assessee filed return of income on the basis of one set of audited financial statements. During the scrutiny proceedings, it filed another set of financial statements wherein additional amount of construction WIP was reported.  The AO made addition as income from undisclosed sources. On appeal the Tribunal held that  there is no change in number of items of inventory of construction WIP as shown in the first set of financial statements as well as second set-Only difference is that in the second set, construction WIP has been valued higher  only for the purpose of consolidated accounts of the venture partner. Amount is only in the nature of notional valuation which has been carried out by the joint venture partner for the purpose of consolidating in its books of account and which cannot be made a basis for addition in the hands of the assessee-Impugned addition deleted. Followed,   CIT v. Laxmi Engineering Industries (2008) 5 DTR (Raj) 106 (HC)   (AY. 2014-15, 2015-16)