Commissioner of Income Tax, Haryana, Rohtak v. Sant Ram Mangat Ram, Ambala City

1. FACTS OF THE CASE

ITR181/1989 concerned AY1982–83 and the Tribunal’s 8 March 1989 order. The referred questions asked whether the ad hoc stock-valuation method was recognised and whether deletion of Rs.1,08,716 for alleged undervaluation of closing gold and silver stock was justified. The Tribunal had followed its decision for AY1981–82.

Source: Question and background, PDF pp.1–2

2. DISCUSSION BY THE COURT

Revenue’s counsel acknowledged that the earlier-year reference, ITR182/1989, had been decided against Revenue on 3 January 2005. The Court followed its earlier view in the same assessee’s case. This two-page judgment does not reproduce the earlier judgment’s accounting analysis.

Source: Reasons, PDF p.2

3. JUDICIAL DECISION

The reference was answered against Revenue and in favour of the assessee, following the earlier-year decision.

Source: Operative paragraph, PDF p.2

4. OUTCOME

Assessee-favourable final answer on the referred stock-valuation questions for AY1982–83. The source establishes the result and its reliance on ITR182/1989, but does not independently explain the valuation method.

Source: PDF pp.1–2

5. Expert Comments

AKHB editorial analysis, distinct from the Court’s findings.

Locate the reasoning in the incorporated precedent

The Court followed its 3 January 2005 decision in ITR182/1989 for AY1981–82. This establishes how the present reference was resolved, but a practitioner asserting a general accounting proposition should obtain that earlier judgment and compare the valuation facts. The question’s reference to an ad hoc method is not itself a full explanation of the method.

Source: PDF p.1 · PDF p.2

Keep years and amounts attached to their proceedings

Rs.1,08,716 is the closing-stock addition questioned for AY1982–83 in ITR181/1989. The earlier AY1981–82 reference supplies the precedent; it is not the same proceeding. Retaining both identities avoids treating successive-year litigation as duplicate records.

Source: PDF p.1 · PDF p.2