Court :
ITAT New Delhi
Brief :
Aggrieved by the order dated 21/12/2018 in appeal No. 324/17-18 passed by the learned Commissioner of Income Tax (Appeals)-XXV, New Delhi (“Ld. CIT(A)”) in the case of Prudent Agri Commodities India Private Limited (resultant company post-merger with the Sunder Agri CommoditiesIndia Private Limited), for the assessment year 2014-15, assessee preferred this appeal on 3 grounds. Ld. AR, however the time of arguments, gave up grounds No. 1 and 2 and confined the arguments to ground No. 3 in respect of the disallowance of forward losses basing on the closing stock for the assessment year 2013-14, which would be the opening stock for the assessment year 2014-15.
Citation :
ITA No.-1499/Del/2019
IN THE INCOME TAX APPELLATE TRIBUNAL
DELHI BENCH: ‘C’ NEW DELHI
BEFORE SHRI G.S. PANNU, HON’BLE VICE PRESIDENT
&
SHRI K.N. CHARY, JUDICIAL MEMBER
ITA No.-1499/Del/2019
(Assessment Year:2014-15)
Prudent-Agri Commodities
India Private limited,
RNM Centre, 68/2, Janpath,
New Dlehi.
PAN No. AAGCP9228E
Appellant
Vs.
ACIT
Special Range-7,
C.R. Building, I.P. Estate,
New Delhi.
Respondent
Revenue by Sh. Gaurav Dudeja, Sr. DR
Assessee by Kanchan Kaushal, Adv.
Sh. Rishabh Malhotra, Adv.
Date of hearing: 30.12.2020
Date of Pronouncement : 30.12.2020
ORDER
PER K. NARASIMHA CHARY, JM
Aggrieved by the order dated 21/12/2018 in appeal No. 324/17-18 passed by the learned Commissioner of Income Tax (Appeals)-XXV, New Delhi (“Ld. CIT(A)”) in the case of Prudent Agri Commodities India Private Limited (resultant company post-merger with the Sunder Agri CommoditiesIndia Private Limited), for the assessment year 2014-15, assessee preferred this appeal on 3 grounds. Ld. AR, however the time of arguments, gave up grounds No. 1 and 2 and confined the arguments to ground No. 3 in respect of the disallowance of forward losses basing on the closing stock for the assessment year 2013-14, which would be the opening stock for the assessment year 2014-15.
2. Brief facts of the case are that the assesseeis a private limited company incorporated under the provisions of the Companies Act, 1956 and is mainly engaged in the trading of agricultural commodity i.e. cotton; that during the immediately preceding year i.e. AY 2013-14, the assessee has valued its closing stock based on Net Realizable Value (NRV), in accordance with the provisions, of Accounting Standards (AS) - 2 ‘Valuation of Inventories’ notified under section 211(3C) of Companies Act, 1956; and thatbased on the accounting policy mentioned above as followed by the assessee, the closing stock had been valued at a value of INR 909,339,489 which is lower than cost price of inventory amounting to INR 935,581,336.
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