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for an amount of Rs.2,84,127 as compared to die value of the items taken for valuation of the opening stock. Since no satisfactory explanation was provided at the time of assessment, therefore, an addition of Rs.2,84,127 made by the A.O. on account of under valuation of the closing stock.

5.2 Upon assessee's appeal, learned CIT(A) noted the assessee's submissions and his adjudication as under:-

"During appellate proceedings, it was submitted that the value of the closing stock was lower as compared to the opening stock due to the decrease in the value of raw material rate per unit. It was also submitted that during the year under consideration, the turnover of the appellant company has significantly increased, as a result overhead expenses per unit were decreased. The detail of raw material consumed and overhead expenses incurred was furnished as Annexure B of the written submission which is reproduced as under:-