CIT v. Dynavision Ltd.

348 ITR 380Supreme Court of India2012#3962 most cited

What is CIT v. Dynavision Ltd. authority for?

The valuation of unsold stock at the close of an accounting period is a necessary part of determining trading results and does not constitute a source of profit. Its purpose is to balance the cost of goods purchased against the closing inventory to reflect actual realized profit or loss from trading.

30

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2014 to 2025.

Also referred to as

CIT v. Dynavision Ltd. · unsold stock valuation · trading results · source of profit · closing inventory · accounting period · realized profit · tax law · section 44AB · section 31

Also reported as

26 Taxmann.com 40210 Taxmann 239

Sections most often in play

Section 143(3)Section 131Section 132Section 132(4)Section 132(4A)Section 153ASection 292CSection 44AB

Issues it is cited on

section 131(1)section 31tangible materialunexplained expendituresection 69csection 132(4)section 131unexplained cash creditsalaryscrutiny assessmentincriminating materialsection 153

Judgments citing CIT v. Dynavision Ltd.

Smithkline Beecham Consumer Brands Ltd vs. Commissioner of Income Tax Patiala

ITR/33/1995HC Punjab & Haryana22 Dec 2025

Bench: MR. JUSTICE AMARINDER SINGH GREWAL,MR. JUSTICE JAGMOHAN BANSAL

Section 143Section 37Section 37(1)

…decided aforesaid issue in ITR-62 to 65-1995. The opinion of Tribunal has been upheld. Appeal of Revenue as well as assessee has been dismissed. The question of inclusion of excise duty in closing stock stands settled in ‘CIT Vs. Dynavision Ltd.’ 348 ITR 380 (SC). The Tribunal has allowed expenses beyond 80% incurred on production of video-film which was displayed on different platforms. Production of video-film is a general business expense which is admissible for deduction under Section 37(1). The Tribunal has wrongly considered said expenses under Section 37(3A and 3B). Production of…

Smithkline Beecham Consumer Brands Ltd vs. Commissioner of Income Tax Patiala

ITR/62/1995HC Punjab & Haryana27 Nov 2025
Section 143Section 35BSection 40Section 40A(5)

…nery as a whole or on the basis of number of days the machinery was put to use stands settled in ‘South India Viscose Ltd. Vs. CIT’ 227 ITR 286 (SC). 7. The question of inclusion of excise duty in closing stock stands settled in ‘CIT Vs. Dynavision Ltd.’ 348 ITR 380 (SC). 8. The assessee has claimed deduction of Rs.25,628/- with respect to air conditioning & coolers, calculators, fans used by research and development department. The revenue claims that these expenses cannot form part of R&D. DEEPAK BISSYAN 2025.12.01 11:06 I attest to the accuracy and integrity of this document ITR-62 to 69-1995…

The Deputy Commissioner of Income Tax, Circle-1(1), Patto Plaza vs. Esteem Industries Private Limited, Plot

ITA 253/PAN/2024[2012-13]Status: DisposedITAT Panaji30 Jun 2025AY 2012-13

Bench: Hon’Ble Shri Pavankumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Mahendra Sanghvi [‘Ld. AR’]For Respondent: Capt. Pradeep Arya [‘Ld. DR’]
Section 143(3)Section 145ASection 250Section 253Section 44A

…IN THE INCOME TAX APPELLATE TRIBUNAL, PANAJI BENCH, PANAJI BEFORE HON’BLE SHRI PAVANKUMAR GADALE, JUDICIAL MEMBER AND SHRI G. D. PADMAHSHALI, ACCOUNTANT MEMBER ITA Nos. 253/PAN/2024 Assessment Year : 2012-13 Dy. Commissioner of Income Tax, Circle-1(1), Panaji, Goa. ................................................... Appellant V/s Esteem Industries Pvt. Ltd. 76-77, Pissurlem Industrial Estate, Pissurlem, Goa-403530. PAN : AAACE9474F ........................................................ Respondent Appearances Assessee by : Mr Mahendra Sanghvi [‘Ld. AR’] Revenue by : Capt. Pradeep Arya [‘Ld. DR’] Date of conclus…

M/S. Lalitha Jewellery Mart Ltd., Chennai vs. DCIT, Central Circle-1(4), Chennai

In the result, all the appeals of the assessee are partly allowed

ITA 679/CHNY/2025[2020-21]Status: DisposedITAT Chennai12 Jun 2025AY 2020-21

Bench: Shri Aby T. Varkey & Shrimanoj Kumar Aggarwal

For Appellant: Mr. D. Anand, AdvocateFor Respondent: Mr. Shiva Srinivas, CIT
Section 132Section 153A

…“source” of such profits.”This position of law was reaffirmed by the Hon’ble Supreme Court This position of law was reaffirmed by the Hon’ble Supreme Court This position of law was reaffirmed by the Hon’ble Supreme Court in the case of CIT v. Dynavision Ltd (348 ITR 380) Dynavision Ltd (348 ITR 380). 38.13 It It It is is is observed observed observed that, that, that, the the the closing closing closing inventory inventory inventory of of of Rs.20,72,47,53,327/- as per the financials for the year as per the financials for the year- -ending 31-03- 2021 was the opening stock for 01 2021 was the opening stock for…

M/S. Lalitha Jewellery Mart Ltd., Chennai vs. DCIT, Central Circle-1(4), Chennai

In the result, all the appeals of the assessee are partly allowed

ITA 678/CHNY/2025[2019-20]Status: DisposedITAT Chennai12 Jun 2025AY 2019-20

Bench: Shri Aby T. Varkey & Shrimanoj Kumar Aggarwal

For Appellant: Mr. D. Anand, AdvocateFor Respondent: Mr. Shiva Srinivas, CIT
Section 132Section 153A

…“source” of such profits.”This position of law was reaffirmed by the Hon’ble Supreme Court This position of law was reaffirmed by the Hon’ble Supreme Court This position of law was reaffirmed by the Hon’ble Supreme Court in the case of CIT v. Dynavision Ltd (348 ITR 380) Dynavision Ltd (348 ITR 380). 38.13 It It It is is is observed observed observed that, that, that, the the the closing closing closing inventory inventory inventory of of of Rs.20,72,47,53,327/- as per the financials for the year as per the financials for the year- -ending 31-03- 2021 was the opening stock for 01 2021 was the opening stock for…

M/S. Lalitha Jewellery Mart Ltd., Chennai vs. DCIT, Central Circle-1(4), Chennai

In the result, all the appeals of the assessee are partly allowed

ITA 677/CHNY/2025[2018-19]Status: DisposedITAT Chennai12 Jun 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shrimanoj Kumar Aggarwal

For Appellant: Mr. D. Anand, AdvocateFor Respondent: Mr. Shiva Srinivas, CIT
Section 132Section 153A

…“source” of such profits.”This position of law was reaffirmed by the Hon’ble Supreme Court This position of law was reaffirmed by the Hon’ble Supreme Court This position of law was reaffirmed by the Hon’ble Supreme Court in the case of CIT v. Dynavision Ltd (348 ITR 380) Dynavision Ltd (348 ITR 380). 38.13 It It It is is is observed observed observed that, that, that, the the the closing closing closing inventory inventory inventory of of of Rs.20,72,47,53,327/- as per the financials for the year as per the financials for the year- -ending 31-03- 2021 was the opening stock for 01 2021 was the opening stock for…

Assistant Commissioner of Income Tax, Circle- 4(1), Raipur vs. M/S Super Iron and Steel Pvt Ltd., Raipur

In the result, appeal of the revenue is partly allowed and Cross objection of the assessee is dismissed

ITA 261/RPR/2017[2010-11]Status: DisposedITAT Raipur31 Oct 2022AY 2010-11

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No.261/Rpr/2017 ("नधा"रण वष" / Assessment Year :2010-2011) Acit-4(1), Raipur Vs M/S Super Iron & Steel Pvt. Ltd., Pritpal Farm House, Vip Road, Raipur(C.G.) Pan No. : Aaics 2579 R (अपीलाथ" /Appellant) .. (""यथ" / Respondent) & Cross Objection No.13/Rpr/2017 (Arising Out Of Ita No.261/Rpr/2017) ("नधा"रण वष" / Assessment Year :2010-2011) M/S Super Iron & Steel Pvt. Ltd., Vs Acit-4(1), Raipur Pritpal Farm House, Vip Road, Raipur(C.G.) Pan No. : Aaics 2579 R (अपीलाथ" /Appellant) (""यथ" / Respondent) ..

For Appellant: Shri Nikhilesh Begani, CAFor Respondent: Shri G.N.Singh, Sr. DR
Section 144Section 40Section 40A(2)(b)Section 68

…must be accepted in the absence of anything to suggest that it is improper or patently false. With respect to valuation of opening and closing stock, the principle of law laid down by the Hon’ble Supreme Court in the case of CIT Vs. Dynavision Ltd reported in 348 ITR 380 is relevant and a binding to be followed, wherein it has been held that:- Section 145 of the Income-tax Act, 1961, read with section 3 of Central Excise Act, 1944 - Method of accounting - Valuation of stock - Assessment year 1987-88 - Assessee was carrying on business of manufacture and sale of television sets - Assessing Officer found that asses…

DCIT, Circle-1(1), Cuttack vs. Shri Dilip Kumar Ghashyamdas Tebrewal, Cuttack

In the result, appeals filed by the revenue are dismissed

ITA 16/CTK/2021[2013-14]Status: HeardITAT Cuttack27 Sept 2022AY 2013-14

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaassessment Year : 2013-14 Dcit, Circle- -1(1) Vs. Sri Sri Ashok Ashok Kumar Kumar Cuttack Ghanshyamdas Ghanshyamdas Tebarewal, Tebarewal, Prop. Prop. Bisandayal Bisandayal Jewellers, Jewellers, Naya Sarak, Cuttack Naya Sarak, Cuttack Pan/Gir No. Pan/Gir No.Aaxpt 7747 E (Appellant (Appellant) .. ( Respondent Respondent) Assessment Year : 2013-14 Dcit, Circle- -1(1) Vs. Sri Sri Dilip Dilip Kumar Kumar Cuttack Ghanshyamdas Ghanshyamdas Tebarewal, Tebarewal, Prop. Prop. Bisandayal Bisandayal Jewellers, Jewellers, Naya Sarak, Cuttack Naya Sarak, Cuttack Pan/Gir No. Pan/Gir No.Aaxpt 7748 E (Appellant (Appellant) .. ( Respondent Respondent)

For Appellant: Shri S.Shivanandan, CIT DRFor Respondent: Shri S.K.Sarangi, CA
Section 40A(2)

…IN THE INCOME TAX APPELLATE TRIBUNAL, IN THE INCOME TAX APPELLATE TRIBUNAL, IN THE INCOME TAX APPELLATE TRIBUNAL, CUTTACK BENCH, CUTTACK BEFORE BEFORE S/SHRI GEORGE MATHAN, JUDICIAL JUDICIAL MEMBER AND ARUN KHODPIA, ACCOUNTANT MEMBER AND ARUN KHODPIA, ACCOUNTANT MEMBER AND ARUN KHODPIA, ACCOUNTANT MEMBER Assessment Year : 2013-14 DCIT, Circle- -1(1) Vs. Sri Sri Ashok Ashok Kumar Kumar Cuttack Ghanshyamdas Ghanshyamdas Tebarewal, Tebarewal, Prop. Prop. Bisandayal Bisandayal Jewellers, Jewellers, Naya Sarak, Cuttack Naya Sarak, Cuttack PAN/GIR No. PAN/GIR No.AAXPT 7747 E (Appellant (Appellant) .. ( Respondent Res…

DCIT, Circle-1(1), Cuttack vs. Shri Asho Kumar Ghanshyamdas Tibarewal, Cuttack

In the result, appeals filed by the revenue are dismissed

ITA 15/CTK/2021[2013-14]Status: HeardITAT Cuttack27 Sept 2022AY 2013-14

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaassessment Year : 2013-14 Dcit, Circle- -1(1) Vs. Sri Sri Ashok Ashok Kumar Kumar Cuttack Ghanshyamdas Ghanshyamdas Tebarewal, Tebarewal, Prop. Prop. Bisandayal Bisandayal Jewellers, Jewellers, Naya Sarak, Cuttack Naya Sarak, Cuttack Pan/Gir No. Pan/Gir No.Aaxpt 7747 E (Appellant (Appellant) .. ( Respondent Respondent) Assessment Year : 2013-14 Dcit, Circle- -1(1) Vs. Sri Sri Dilip Dilip Kumar Kumar Cuttack Ghanshyamdas Ghanshyamdas Tebarewal, Tebarewal, Prop. Prop. Bisandayal Bisandayal Jewellers, Jewellers, Naya Sarak, Cuttack Naya Sarak, Cuttack Pan/Gir No. Pan/Gir No.Aaxpt 7748 E (Appellant (Appellant) .. ( Respondent Respondent)

For Appellant: Shri S.Shivanandan, CIT DRFor Respondent: Shri S.K.Sarangi, CA
Section 40A(2)

…IN THE INCOME TAX APPELLATE TRIBUNAL, IN THE INCOME TAX APPELLATE TRIBUNAL, IN THE INCOME TAX APPELLATE TRIBUNAL, CUTTACK BENCH, CUTTACK BEFORE BEFORE S/SHRI GEORGE MATHAN, JUDICIAL JUDICIAL MEMBER AND ARUN KHODPIA, ACCOUNTANT MEMBER AND ARUN KHODPIA, ACCOUNTANT MEMBER AND ARUN KHODPIA, ACCOUNTANT MEMBER Assessment Year : 2013-14 DCIT, Circle- -1(1) Vs. Sri Sri Ashok Ashok Kumar Kumar Cuttack Ghanshyamdas Ghanshyamdas Tebarewal, Tebarewal, Prop. Prop. Bisandayal Bisandayal Jewellers, Jewellers, Naya Sarak, Cuttack Naya Sarak, Cuttack PAN/GIR No. PAN/GIR No.AAXPT 7747 E (Appellant (Appellant) .. ( Respondent Res…

Kisan Sahkari Chini Mills Ltd., Pilibhit vs. Astt. Commissioner of Income Tax, Bareilly

In the result, all the appeals are allowed for statistical purposes

ITA 776/LKW/2016[2008-09]Status: DisposedITAT Lucknow07 Apr 2022AY 2008-09

Bench: Shri A.D Jain & Shri T.S. Kapoor

Section 145A

…dition by holding that Section 145A was amended w.e.f. 1.4.1999 which required that excise duty should be included in the valuation of closing stock. It was submitted that the decision of the Hon'ble Supreme Court in the case of CIT vs. Dynavision Ltd. [2012] 348 ITR 380 (SC) has clearly held that excise duty in the closing stock can be taken into account if the same has been debited in the trading or P&L account. The ld. AR submitted that it is a fact that assessee has not debited the excise duty in the trading of P&L account therefore ld. CIT(A) has wrongly sustained the addition and it was prayed that the same…

Kisan Sahkari Chini Mills Ltd., Pilibhit vs. Astt. Commissioner of Income Tax, Bareilly

In the result, all the appeals are allowed for statistical purposes

ITA 775/LKW/2016[2007-08]Status: DisposedITAT Lucknow07 Apr 2022AY 2007-08

Bench: Shri A.D Jain & Shri T.S. Kapoor

Section 145A

…dition by holding that Section 145A was amended w.e.f. 1.4.1999 which required that excise duty should be included in the valuation of closing stock. It was submitted that the decision of the Hon'ble Supreme Court in the case of CIT vs. Dynavision Ltd. [2012] 348 ITR 380 (SC) has clearly held that excise duty in the closing stock can be taken into account if the same has been debited in the trading or P&L account. The ld. AR submitted that it is a fact that assessee has not debited the excise duty in the trading of P&L account therefore ld. CIT(A) has wrongly sustained the addition and it was prayed that the same…

Kisan Sahkari Chini Mills Ltd., Pilibhit vs. Astt. Commissioner of Income Tax, Bareilly

In the result, all the appeals are allowed for statistical purposes

ITA 774/LKW/2016[2006-07]Status: DisposedITAT Lucknow07 Apr 2022AY 2006-07

Bench: Shri A.D Jain & Shri T.S. Kapoor

Section 145A

…dition by holding that Section 145A was amended w.e.f. 1.4.1999 which required that excise duty should be included in the valuation of closing stock. It was submitted that the decision of the Hon'ble Supreme Court in the case of CIT vs. Dynavision Ltd. [2012] 348 ITR 380 (SC) has clearly held that excise duty in the closing stock can be taken into account if the same has been debited in the trading or P&L account. The ld. AR submitted that it is a fact that assessee has not debited the excise duty in the trading of P&L account therefore ld. CIT(A) has wrongly sustained the addition and it was prayed that the same…

Siroya Developers, Mumbai vs. ITO 17(3)(3), Mumbai

The appeal of the assessee is partly allowed in terms of our aforesaid observations

ITA 409/MUM/2017[2009-10]Status: DisposedITAT Mumbai10 Sept 2020AY 2009-10

Bench: Shri S. Rifaur Rahman & Shri Ravish Soodm/S Siroya Developers Ito-17(3)(3)[Previously Assessed 101, Kingston Towers, With Acit-31(3)], Gd Ambekar Marg, Parel Tank Mumbai Road, Parel – East, Vs. Mumbai – 400 033

For Appellant: Shri B.V Jhaveri, A.RFor Respondent: Shri. Avaneesh Tiwari, D.R
Section 143(3)Section 263Section 80I

…e close of the accounting period is a necessary part of the process of determining the trading results of that period and cannot be regarded as a source of profit. In fact, as observed by the Hon’ble Supreme Court in the case of CIT Vs. Dynavision Ltd. (2012) 348 ITR 380 (SC), the true purpose of crediting the value of unsold stock is to balance the cost of the goods entered on the other side of the account at the time of the purchase, so that, on cancelling out of the entries relating to the same stock from both sides of the account would leave only the transactions in which actual sales in the course of the yea…

Mahashakti Engineering Co., Ghaziabad vs. DCIT, New Delhi

In the result, the appeal filed by the assessees is partly allowed

ITA 1940/DEL/2016[2009-10]Status: DisposedITAT Delhi22 Jul 2019AY 2009-10

Bench: Shri R.K. Panda & Shri Kuldip Singhassessment Year: 2009-10 Mahashakti Engineering Co., Vs Dcit, C/O Akhilesh Kumar, Advocate, Circle-21(1), Chamber No.206-07, Ansal ‘Satyam’, New Delhi. Rdc Raj Nagar, Ghaziabad. Pan: Aaofm9129J (Appellant) (Respondent) Assessee By : Shri Akhilesh Kumar, Advocate Revenue By : Ms Ashima Neb, Sr. Dr Date Of Hearing : 15.07.2019 Date Of Pronouncement : 22.07.2019 Order Per R.K. Panda, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 20Th March, 2015 Of The Cit(A)-13, New Delhi Relating To Assessment Year 2009-10. 2. The Grounds Of Appeal No.1 & 2 Raised By The Assessee Read As Under:-

For Appellant: Shri Akhilesh Kumar, AdvocateFor Respondent: Ms Ashima Neb, Sr. DR

…ing on various decisions, the ld. counsel for the assessee submitted that no addition can be made to closing stock without making adjustment to opening stock. Referring to the decision of the Hon'ble Supreme Court in the case of CIT vs. Dynavision Ltd. (2012) 348 ITR 380 (SC), he submitted that the Hon'ble Supreme 6 Court in the said decision has held that where the assessee had been consistently following the method of valuation of closing stock and the Assessing Officer revalued the closing stock without making any adjustment to opening stock, any addition on account of under valuation of closing stock was u…

Kansai Nerolac Paints Ltd, Mumbai vs. Addl CIT RG 6(2), Mumbai

ITA 7196/MUM/2013[2007-08]Status: DisposedITAT Mumbai15 May 2019AY 2007-08

Bench: Shri Mahavir Singh & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.6789/Mum/2013 (नििाारण वर्ा / Assessment Year: 2007-08) बिाम/ Dcit Circle -6(2) M/S. Kansai Nerolac Paints Ltd., R.No. 563, Aayakar Bhavan, Nerolac House, K.G. Marg, M.K. Road, Churchgate, V. Lower Parel, Mumbai-400020 Mumbai-400013 स्थायी ऱेखा सं./ Pan :Aaacg1376N (अपीऱाथी /Appellant) (प्रत्यथी / Respondent) .. आयकर अपीऱ सं./I.T.A. No.7196/Mum/2013 (नििाारण वर्ा / Assessment Year: 2007-08) बिाम/ M/S. Kansai Nerolac Paints Addl. Cit Circle -6(2) Ltd., R.No. 669, Nerolac House, K.G. Marg, Aayakar Bhavan, V. Lower Parel, Mumbai 400013 M.K. Road, Mumbai- 400020 स्थायी ऱेखा सं./ Pan : Aaacg1376N (अपीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Ms. Aarti VissanjiFor Respondent: Shri. Rignesh K. Das (DR)
Section 143(3)Section 144C(3)Section 145ASection 14A

…change at the other end (on 1-4-2006 as in the instant case) otherwise, the true profit would not be reflected. This view of Privy Council is further fortified and supported by the decision of Hon'ble Supreme Court in the case of CIT v. Dynavision Ltd. [2012] 348 ITR 380/210 Taxman 239/26 taxmann.com 40. The reliance of the Revenue on the decision of Hon'ble Bombay High Court in Molmould Corporation (supra) is devoid of merits as in the said case the taxpayer was regularly following method of valuation of inventory at cost plus overhead and then during the impugned assessment year, the taxpayer chose to change me…

DCIT 6(2), Mumbai vs. Kansai Nerolac Paints Ltd, Mumbai

ITA 6789/MUM/2013[2007-08]Status: DisposedITAT Mumbai15 May 2019AY 2007-08

Bench: Shri Mahavir Singh & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.6789/Mum/2013 (नििाारण वर्ा / Assessment Year: 2007-08) बिाम/ Dcit Circle -6(2) M/S. Kansai Nerolac Paints Ltd., R.No. 563, Aayakar Bhavan, Nerolac House, K.G. Marg, M.K. Road, Churchgate, V. Lower Parel, Mumbai-400020 Mumbai-400013 स्थायी ऱेखा सं./ Pan :Aaacg1376N (अपीऱाथी /Appellant) (प्रत्यथी / Respondent) .. आयकर अपीऱ सं./I.T.A. No.7196/Mum/2013 (नििाारण वर्ा / Assessment Year: 2007-08) बिाम/ M/S. Kansai Nerolac Paints Addl. Cit Circle -6(2) Ltd., R.No. 669, Nerolac House, K.G. Marg, Aayakar Bhavan, V. Lower Parel, Mumbai 400013 M.K. Road, Mumbai- 400020 स्थायी ऱेखा सं./ Pan : Aaacg1376N (अपीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Ms. Aarti VissanjiFor Respondent: Shri. Rignesh K. Das (DR)
Section 143(3)Section 144C(3)Section 145ASection 14A

…change at the other end (on 1-4-2006 as in the instant case) otherwise, the true profit would not be reflected. This view of Privy Council is further fortified and supported by the decision of Hon'ble Supreme Court in the case of CIT v. Dynavision Ltd. [2012] 348 ITR 380/210 Taxman 239/26 taxmann.com 40. The reliance of the Revenue on the decision of Hon'ble Bombay High Court in Molmould Corporation (supra) is devoid of merits as in the said case the taxpayer was regularly following method of valuation of inventory at cost plus overhead and then during the impugned assessment year, the taxpayer chose to change me…

Ksc Engineers Private Ltd., New Delhi vs. DCIT, New Delhi

In the result appeal filed by assessee stands dismissed

ITA 5224/DEL/2016[2012-13]Status: DisposedITAT Delhi06 Sept 2018AY 2012-13

Bench: Shri R.K.Panda & Smt. Beena A Pillaiassessment Year : 2011-12 M/S Ksc Engineers Vs. Acit, Circle 14(2) Pvt.Ltd. Room No.311A 4-H, Gopala Tower 3Rd Floor, C.R.Building Rajendra Place I.P.Estate New Delhi 110 008 New Delhi 110 002 Pan: Aaack6112C Assessment Year : 2011-12 Acit, Circle 14(2) Vs. M/S Ksc Engineers Pvt.Ltd. Room No.311A 4-H, Gopala Tower 3Rd Floor, C.R.Building Rajendra Place I.P.Estate New Delhi 110 008 New Delhi 110 002 Pan: Aaack6112C Assessment Year : 2012-13 M/S Ksc Engineers Vs. Acit, Circle 14(2) Pvt.Ltd. Room No.311A 4-H, Gopala Tower 3Rd Floor, C.R.Building Rajendra Place I.P.Estate New Delhi 110 008 New Delhi 110 002 Pan: Aaack6112C (Appellant) (Respondent)

Section 143(2)Section 143(3)Section 36(1)(iii)

…3209/Del/2016 Asst.Yr.12-13 M/s KSC Engineers P Ltd. vs. ACIT High Court in the case of Wolkem -India Ltd. and P&H High Court in the case of Sant Ram Mangat Ram in the decisions cited supra. The Hon'ble Supreme court in the case of CIT vs. Dynavision Ltd. (348 ITR 380) has held that when an assessee has been consistently following the method of valuation of closing stock at cost or market price, whichever is lower, any addition on account of under valuation of closing stock was unjustified more so when the AO revalued the closing stock without making any adjustment to the opening stock. In this decision, the S…

ACIT, New Delhi vs. M/S. Ksc Engineers Pvt. Ltd., New Delhi

In the result appeal filed by assessee stands dismissed

ITA 3209/DEL/2016[2011-12]Status: DisposedITAT Delhi06 Sept 2018AY 2011-12

Bench: Shri R.K.Panda & Smt. Beena A Pillaiassessment Year : 2011-12 M/S Ksc Engineers Vs. Acit, Circle 14(2) Pvt.Ltd. Room No.311A 4-H, Gopala Tower 3Rd Floor, C.R.Building Rajendra Place I.P.Estate New Delhi 110 008 New Delhi 110 002 Pan: Aaack6112C Assessment Year : 2011-12 Acit, Circle 14(2) Vs. M/S Ksc Engineers Pvt.Ltd. Room No.311A 4-H, Gopala Tower 3Rd Floor, C.R.Building Rajendra Place I.P.Estate New Delhi 110 008 New Delhi 110 002 Pan: Aaack6112C Assessment Year : 2012-13 M/S Ksc Engineers Vs. Acit, Circle 14(2) Pvt.Ltd. Room No.311A 4-H, Gopala Tower 3Rd Floor, C.R.Building Rajendra Place I.P.Estate New Delhi 110 008 New Delhi 110 002 Pan: Aaack6112C (Appellant) (Respondent)

Section 143(2)Section 143(3)Section 36(1)(iii)

…3209/Del/2016 Asst.Yr.12-13 M/s KSC Engineers P Ltd. vs. ACIT High Court in the case of Wolkem -India Ltd. and P&H High Court in the case of Sant Ram Mangat Ram in the decisions cited supra. The Hon'ble Supreme court in the case of CIT vs. Dynavision Ltd. (348 ITR 380) has held that when an assessee has been consistently following the method of valuation of closing stock at cost or market price, whichever is lower, any addition on account of under valuation of closing stock was unjustified more so when the AO revalued the closing stock without making any adjustment to the opening stock. In this decision, the S…

M/S. Ksc Engineers Private Limited, New Delhi vs. DCIT, New Delhi

In the result appeal filed by assessee stands dismissed

ITA 2417/DEL/2016[2011-12]Status: DisposedITAT Delhi06 Sept 2018AY 2011-12

Bench: Shri R.K.Panda & Smt. Beena A Pillaiassessment Year : 2011-12 M/S Ksc Engineers Vs. Acit, Circle 14(2) Pvt.Ltd. Room No.311A 4-H, Gopala Tower 3Rd Floor, C.R.Building Rajendra Place I.P.Estate New Delhi 110 008 New Delhi 110 002 Pan: Aaack6112C Assessment Year : 2011-12 Acit, Circle 14(2) Vs. M/S Ksc Engineers Pvt.Ltd. Room No.311A 4-H, Gopala Tower 3Rd Floor, C.R.Building Rajendra Place I.P.Estate New Delhi 110 008 New Delhi 110 002 Pan: Aaack6112C Assessment Year : 2012-13 M/S Ksc Engineers Vs. Acit, Circle 14(2) Pvt.Ltd. Room No.311A 4-H, Gopala Tower 3Rd Floor, C.R.Building Rajendra Place I.P.Estate New Delhi 110 008 New Delhi 110 002 Pan: Aaack6112C (Appellant) (Respondent)

Section 143(2)Section 143(3)Section 36(1)(iii)

…3209/Del/2016 Asst.Yr.12-13 M/s KSC Engineers P Ltd. vs. ACIT High Court in the case of Wolkem -India Ltd. and P&H High Court in the case of Sant Ram Mangat Ram in the decisions cited supra. The Hon'ble Supreme court in the case of CIT vs. Dynavision Ltd. (348 ITR 380) has held that when an assessee has been consistently following the method of valuation of closing stock at cost or market price, whichever is lower, any addition on account of under valuation of closing stock was unjustified more so when the AO revalued the closing stock without making any adjustment to the opening stock. In this decision, the S…

The DCIT, 1(1), Indore vs. M/S Mittal Corp. Ltd., Mumbai

In the result, both the appeals of the revenue stand

ITA 660/IND/2013[2009-10]Status: DisposedITAT Indore27 Jun 2018AY 2009-10

Bench: Shri Kul Bharat, Hon’Ble & Shri Manish Borad, Hon’Ble

Section 143(2)Section 143(3)Section 145ASection 36(1)(iii)Section 40A

…a distorted figure. In this respect, I keep reliance on following judicial pronouncements : 1. CIT v. Indo Nippon Chemicals Ltd. (2003) 261 ITR 275 (SC) 2. CIT vs. Shri Ram Honda Power Equipment Limited 2012 – TIOl -88- S.C. 3. CIT vs. Dynavision Ltd. (2012) 348 ITR 380 (S.C.) 4. Chainrup Sampatram vs. CIT (1953) 24 ITR 481 (S.C.) 5.M/s Rajratan Globe Wire Ltd. vs. ACIT;ITA No.768/Ind/2006 6.ACIT vs. M/s Tesla Transformers 2010 15 ITJ 877 (Tribunal) Indore 7. ACIT vs. D&H Secheron Electrodes (P) Ltd. 173 Taman 188 4.6 In the aforestated facts of the appellant’s case, I have considered the A.O.’s order as well…

CIT v. Dynavision Ltd. (348 ITR 380) — Cited in 30 Judgments | BharatTax