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The learned CIT(A) has grossly erred by not accepting the facts that stock of petrol and diesel taken over due to taking up over the demerged business of GSPC is already considered and accounted by the appellant in the books of accounts for the F.Y. 2006-07. The learned CIT(A) failed to appreciate that only w.e.f. F.Y. 07-08 (A.Y. 08-09) the ITA Nos.3117 &2958/Ahd/2010, 1390 &1300/Ahd/2012, 239 & 678/Ahd/2013 GSPC Gas Co.Ltd. vs. JCIT/ACIT Asst.Years - 2007-08, 2008-09 & 2009-10 appellant changed its accounting policy for 'Line Pack Gas" and consequently the stock of Natural Gas as Line Pack as at 31st March, 2008 would continue to remain a an inventory with the company and also since the company as an opinion either to purchase the same at the end of the agreement with the supplier or return it back to the supplier, the company has decided to account for the same as an inventory as at 31st March, 2008, which up to the financial year 2006-07 was charged to the profit & loss account. The learned CIT(A) has further failed to understand that by making addition of the Closing stock for A.Y. 2006- 07 (A.Y. 2007-08) it will automatically become opening stock for F.Y. 2007-08 (A.Y. 2008-09) and thus revenue effect will be Nil. The learned CIT(A) has grossly erred in rejecting the book results. He has failed to understand that accounts of the appellant are audited by internal auditors, statutory auditors, Tax Auditors and even C & AG of India.

09) and thus revenue effect would be NIL. He submitted that the ld.CIT(A) has grossly erred in rejecting the book result. He submitted that the ld.CIT(A) has failed to appreciate that accounts of the assessee are audited by internal auditors, statutory auditors, tax auditors and even C&AG of India. He submitted that the ld.CIT(A) has also failed to appreciate that the ld.A.O. has accepted the book results. He submitted that it was submitted before the ld.CIT(A) that F.Y.2006-07 (AY 2007-

"Notes:
Difference in reconciliation of purchases and sales of gas quantities is on account of measurement tolerance and normal loss. Also, the purchase is effected mostly in Energy terms (MMBTU / Kcals etc) While the sale is done in terms of Volume (SCM), hence both the figures may not be comparable. Sale in value of CNG is net of discounts and excise duty."

1.4 The learned CIT(A) has failed to understand the fact that by confirming the addition of the Closing stock for F.Y. 07-08 {A.Y 08-09) the closing stock will automatically become the opening stock of the next year for F.Y. 08-09 (A.Y. 09-10) and the revenue loss will be Nil which is in line with the following judgments a. Chattar Extractions Pvt. Ltd. Vs. ITO (2004) 85 TTJ (Asr)(TM) 405 : (2004) 91 ITD 385 (Asr)(TM) b. West Coast Paper Mills Ltd. Vs. ACIT (2006) 105 TTJ (Mumbai) 344 : (2006) 106 ITD 19 (Mumbai), c. Cyanamid Agro Ltd. Vs. Addl. CIT (2009) 121 TTJ (Mumbai) 606 : (2009) The learned CIT(A) has grossly erred in rejecting the book results. He has failed to understand that accounts of the appellant are audited by internal auditors, statutory auditors, Tax Auditors and even CA & AG of India.