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2,5. So far as valuation of finished goods is concerned, appellant has shown such stock at Rs.2442.91 per MT whereas AO has adopted 2650 per MT and made addition of Rs.36,35,672/-. The appellant has claimed that such stock has been valued as per cost method. It is observed that appellant has not provided any scientific basis for arriving at cost of 2442.91 per MT in assessment proceedings as well appellate proceedings, it is also observed that even though average purchase price of sale has been increased to 777.42 per MT from opening stock of raw material at Rs 748.22 per Sq meter, appellant has not explained why closing stock of finished goods have been reduced substantially from 2740.58 per MT to 2442.91 per MT. It is general principal of accountancy that closing stock of finished goods mainly comprises of raw material purchase price and direct manufacturing overheads. In present year, average purchase price of raw material has increased in comparison with opening stock which always lead to increase in closing rate of finished goods. Though overall overhead expenses has been reduced in current year in comparison with earlier assessment year, but such decrease is mainly due to decrease in turnover of the appellant company. The appellant has not proved that overall direct overhead expenditure like electricity, wages, other manufacturing expenses have been substantially reduced in current year and reasons for such reduction of expenditure to justify its claim for valuing closing stock at substantially lower value when facts current year have remained same with earlier year. As closing stock valuation adopted by appellant was not showing true and correct fact, AO was justified in adopting I.T.A No. 898/Ahd/2018 A.Y. 2013-2014 Page No 5 Chirai Salt (India) Pvt. Ltd. vs. DCIT rate considered by appellant for making disclosure in survey proceedings at most appropriate rate hence addition made by AO considering closing stock at Rs 2650 per MT is considered as reasonable and addition made by AO is upheld. Thus, addition made by AO for Rs.47J9.799/- is upheld. This ground of appeal is dismissed.