RELEVANT PARAGRAPH
3. As regards the issue raised with regard to rejecting the method in the change of valuation of closing stock, we find that the finding arrived at by the three authorities below that the change in the valuation of closing stock was not bona fide is a pure finding of fact and no question of law arises much less a substantial question of law. We also agree that the change in the method of valuation of the closing stock was not bona fide because the authorities below have noted that for the assessment year in question seeking of change in the method of valuation of the closing stock was in the year where there were huge rise in the profits of the assessee company and the change was adopted in order to reduce profits in the relevant year. The fact that the change is not bona fide is more than abundantly clear from the fact that the assessee once again switched back to the old method of valuation of closing stock just one year thereafter in the assessment year 1993-94. The contention of the counsel for the appellant that assessee company was entitled to follow a scientific basis for valuation of the closing stock is not in issue because no doubt a company can adopt such a method for valuation of the closing stock, but, such valuation of closing stock had to be adopted on a consistent basis and cannot be changed to suit the convenience of the assessee so as to deprive the revenue of legitimate tax. It is rightly been found by all the authorities below that the change in the valuation stock was not bona fide. Nothing further need be said on this aspect.
