In the light of the above, we are of the view that the earlier decision of this court in Popular Workshops v. CIT [1987] 166 ITR 348 does not require reconsideration.
In the assessment, the Income-tax Officer took the view that the closing stock which was distributed among the partners on dissolution should have been valued not at the cost price but at the market price. After the applicant/assessee-firm was dissolved, two new firms, dealing in motor vehicle spare parts, were constituted. The Income-tax Officer made an addition of Rs. 6,63,202 in the valuation of the closing stock of the spare parts adopting the market price. He relied on the decisions of the Madras High Court in G. R. Ramachari and Co. v. CIT [1961] 41 ITR 142 and A. L. A. Firm v. CIT [1976] 102 ITR 622. In appeal, the Commissioner of Income-tax (Appeals) deleted the addition. In further appeal by the Revenue, the Income-tax Appellate Tribunal held that the privilege of valuing the opening and closing stock in a consistent manner was available only to a continuing business and it would not be adopted where a business has come to an end and the stock on hand had to be disposed of in order to determine the exact position of the business on the date of the closure.
In the assessment, the Income-tax Officer took the view that the closing stock which was distributed among the partners on dissolution should have been valued not at the cost price but at the market price. After the applicant/assessee-firm was dissolved, two new firms, dealing in motor vehicle spare parts, were constituted. The Income-tax Officer made an addition of Rs. 6,63,202 in the valuation of the closing stock of the spare parts adopting the market price. He relied on the decisions of the Madras High Court in G. R. Ramachari and Co. v. CIT [1961] 41 ITR 142 and A. L. A. Firm v. CIT [1976] 102 ITR 622. In appeal, the Commissioner of Income-tax (Appeals) deleted the addition. In further appeal by the Revenue, the Income-tax Appellate Tribunal held that the privilege of valuing the opening and closing stock in a consistent manner was available only to a continuing business and it would not be adopted where a business has come to an end and the stock on hand had to be disposed of in order to determine the exact position of the business on the date of the closure.