Synergy Telecommunications Vs DCIT (ITAT Chandigarh)
Obsolete Stock Cannot Be Valued on the AO’s “It Must Have Some Value” Theory: ₹59.79 Crore Write-Off Allowed Under AS-2
The Chandigarh ITAT has allowed the write-off of obsolete telecom inventory amounting to ₹59.79 crore, holding that the AO cannot substitute an assessee’s valuation based on the recognised method of lower of cost or net realisable value merely on the presumption that the stock must possess some scrap value.
Where the assessee had followed Accounting Standard-2, physically verified the inventory, furnished item-wise details, obtained certification from its auditor and demonstrated the commercial circumstances that rendered the stock obsolete, the burden shifted to the Revenue to establish a higher realisable value through positive evidence. An assumed scrap value without market quotations, comparable transactions, technical valuation or identification of prospective buyers could not justify rejection of the assessee’s valuation.
The assessee was engaged in manufacturing sheet-metal products and providing telecom tower solutions, including intelligent power interfaces, cool shelters, air conditioners & towers. Its business suffered severely following the disruption in the telecom industry associated with the 2G spectrum controversy during FY 2011-12. The relevant business line eventually became commercially unviable and was discontinued.
For AY 2015-16, the assessee had opening stock of approximately ₹53.02 crore, purchases of ₹2.91 crore and sales of ₹4.99 crore. The closing stock was valued at ₹3.22 crore after writing down obsolete and non-moving inventory. The total reduction on account of obsolete stock was ₹59.79 crore.
The assessee explained that the old telecom equipment and components had lost their utility and marketability. The inventory was physically verified by the management in consultation with the auditors and valued at its net realisable value. Since a substantial portion could not be sold in the market, its realisable value was taken at nil. The valuation was stated to be in conformity with AS-2 issued by the ICAI, which requires inventory to be valued at cost or net realisable value, whichever is lower.
The assessee’s financial deterioration was also evident from its turnover. Sales of ₹29.25 crore and ₹49.27 crore in AYs 2011-12 & 2012-13 respectively fell sharply to ₹7.82 crore and ₹3.09 crore in AYs 2013-14 & 2014-15. Sales during the year under consideration were only ₹4.99 crore, despite the assessee historically carrying inventory exceeding ₹50 crore. Its bank account with SBI was also classified as a non-performing asset.
The AO rejected the write-off. SBI informed the Department that it had not received any communication from the assessee regarding the stock valuation. The AO also noticed that 96 items appearing in the stock summary as on 31.03.2014 did not appear in the summary as on 31.03.2015. According to him, the stock could not have become completely valueless because it would necessarily possess some scrap value.
The certificates furnished by the partner and auditor were treated as self-serving because they were not supported by a report from an independent technical expert. The AO consequently disallowed the entire reduction of ₹59.79 crore. The CIT(A) confirmed the disallowance, observing that the tax audit report did not separately report the massive write-off as an exceptional or extraordinary item and that the basis for valuing the items at nil was unclear.
The Tribunal rejected this approach. It observed that valuation of closing stock is not confined to its historical cost. Inventory cannot be carried at an amount higher than what is expected to be realised through its sale or use. Where stock becomes obsolete, commercially unusable or non-marketable, its net realisable value, rather than its original cost, becomes decisive.
The assessee had consistently followed the method of valuing inventory at the lower of cost or net realisable value. The tax auditor did not report any change or deviation from that method. Item-wise stock records were maintained, physical verification was undertaken and the valuation was reflected in the audited accounts.
The ITAT held that there is no statutory requirement that every valuation of obsolete inventory must be certified by an independent technical expert. Management is entitled to exercise commercial judgment while estimating net realisable value, provided the method is recognised, consistently followed and reasonably supported.
The AO had not conducted an independent valuation. He did not identify which items possessed scrap value, quantify such value, obtain market quotations, cite comparable sales or demonstrate that any purchaser was willing to acquire the obsolete items. The conclusion that some scrap value “must” exist was merely a presumption.
The Tribunal relied upon CIT v. Alfa Laval (India) Ltd. [2007] 295 ITR 45 (SC). In that case, the Revenue substituted the assessee’s valuation of obsolete stock without disclosing a cogent basis. The assessee’s valuation, supported by its auditor and subsequent realisation, was accepted. The principle was that the Revenue must possess credible material before replacing a valuation made according to a recognised accounting method.
The decision in Dr. Reddy’s Laboratories Ltd. [2025] 174 taxmann.com 238 was distinguished. That case involved a separate provision for inventory obsolescence while computing book profit u/s 115JB, even though reduction in value had already been accounted for under the lower-of-cost-or-NRV method. The present case involved the direct valuation of closing stock itself and not an additional provision claimed over and above such valuation.
The Tribunal also noticed that the closing stock of AY 2015-16 became the opening stock of AY 2016-17, and the latter was accepted in the scrutiny assessment for the next year without adverse inference. If the closing stock were enhanced in the present year, the opening stock of the following year would correspondingly increase, resulting in a higher business loss. The exercise was therefore substantially tax neutral across the two years.
Accordingly, the ITAT allowed the write-off, directed the AO to recompute the income or loss and permit the resultant loss to be carried forward.
Author’s Comment
The decision does not lay down that every claim of obsolete stock must be accepted merely because it is certified by management or an auditor. The assessee must demonstrate the nature of the stock, the commercial reasons for obsolescence, the valuation method followed and the supporting inventory records.
However, once the assessee produces such material and follows a recognised accounting standard, the AO cannot reject the valuation through conjecture. The assertion that stock “must have scrap value” is not a valuation exercise. If the Revenue proposes a higher value, it must support that value with market evidence, technical material, comparable sales or an independent valuation.
The ruling can be summed up neatly: the AO may question a nil net realisable value, but he cannot replace it with an imaginary value; suspicion is not a substitute for valuation.
Cases Discussed
- CIT Vs. Alfa Laval (India) Ltd. [2007] 295 ITR 45 (SC)
- Alfa Laval (India) Ltd. Vs. DCIT (Bombay High Court)
- Dr. Reddy’s Laboratories Ltd. [2025] 174 taxmann.com 238
FULL TEXT OF THE JUDGMENT/ORDER OF ITAT CHANDIGARH
1. Aforesaid appeal by assessee for Assessment Year (AY) 2015-16 arises out of an order of learned Commissioner of Income Tax (Appeals) – 3, Gurgaon [CIT(A)] dated 12.09.2025 in the matter of an assessment framed by Ld. Assessing Officer [AO] u/s 143(3) of the Act on 21.12.2017. The sole grievance of the assessee is confirmation of addition of obsolete stock as written-off by the assessee during the year.
2. The Ld. AR advanced arguments and referred to various documents as placed in the paper book. Reference has been made to various judicial decisions to support the case of the assessee. The Ld. CIT-DR, on the other hand, referred to the findings of lower authorities and argued that the claim was not substantiated with requisite documents. Having heard rival submissions and upon perusal of case records, the appeal is disposed-off as under.
Assessment Proceedings
3.1 During assessment proceedings of assessee-firm, the main issue arose on account of write-off of obsolete stock. It transpired that the assessee had opening stock of approx. Rs.60 Crores which was written-off as obsolete stock. The assessee’s banker State Bank of India (SBI) also classified assessee’ account as Non-performing asset (NPA) during the year due to obsolete condition of stock and assessee’s default in repayment of debts. The auditor reported that the valuation of stock was done on the basis of ICAI Accounting Standard-2 (AS-2) Valuation of inventories which mandate valuation of stock at lower of cost or net realizable value. The management, in consultation with its auditors and bankers, undertook physical verification of actual stock and valued it on the basis of net realizable value. Accordingly, the excess stock was written-off. It was pointed out by the assessee that the stock was very old stock and the assessee’s business suffered heavily due to telecom scam which occurred during FY 2011-12. The assessee was stated to be engaged as sheet metal manufacturer which provided telecom tower solutions for various telecom operators.
It focused on developing intelligent power interfaces, cool shelters, air conditioners and towers. However, Ld. AO found that the assessee’s banker SBI stated that no communication was received from the assessee regarding valuation of stock. In further support of its contention, the assessee furnished item-wise details of closing stock as on 31.03.2015 and as many as 96 items were found missing in stock summary as on 31.03.2015 in comparison to stock as on 31.03.2014.
3.2 The Ld. AO noted that the assessee had opening stock of Rs.53.02 Crores and it made purchase of Rs.2.91 Crores during the year. The assessee reflected sales of Rs.4.99 Crores and the closing stock was valued at Rs.3.22 Crores. The above stated missing items were not utilized for production. The value of stock could not be zero since some scrap value would be attached to these items. It was finally alleged that the revaluation of the stock was done as per the convenience of the assessee. No documents were furnished to show that the stock became obsolete.
3.3 The assessee furnished certificate of its partner and auditor in support of the same. However, the said certificate was not signed by any technical expert and therefore, the valuation was held to be self-serving document which was not supported by any evidence or technical report etc. Therefore, the reduction in stock for Rs.59.79 Crores was disallowed while framing the assessment.
Appellate Proceedings
4.1 The assessee, in its written submission, stated that it was engaged in manufacturing of shelters of telecommunication towers. It wrote-off excess stock due to the fact that it discontinued its business owing to 2G spectrum scam and substantial stock was not capable of being sold in the open market. Consequently, the stock had no realizable value and accordingly, written-off in the books by way of correct valuation of closing stock. It was further stated that the assessee discontinued this line of business and found the business to be unviable. The stock became obsolete and the assessee adopted consistent method of valuation of inventories i.e., lower of cost or net realizable value as prescribed by AS-2 of ICAI. Such stock could not be sold in the market and therefore, the net realizable value for such stock was taken as ‘nil’. This method of valuation was in accordance with the valuation method as prescribed by ICAI and therefore, the write-off was allowable to the assessee in terms of various judicial decisions. It was further stated that old stock was lying with the assessee due to which the quality of the stock deteriorated and the firm was left with no option but to dump the obsolete stock as scrap. The bank account was classified as NPA for the same very reasons. The auditor confirmed valuation of inventories as per AS-2. No justification was given by Ld. AO as to why the value of certain items of stock could not be ‘nil’. The Ld. AO did not make any enquiry about the nature of stock; whether the same had any scrap value in the open market or not etc. The assessee fulfilled its duties regarding justification of value taken for closing stock by furnishing certificate from its auditor and after following AS-2, valued the stock. Reference was made to the decision of Hon’ble Apex Court in the case of CIT vs. Alfa Laval (India) Limited (295 ITR 45) which was rendered in assessee’s favor on similar facts.
4.2 The Ld. CIT(A) maintained that assessee’s banker SBI, vide its reply dated 19.12.2017, clarified that they did not receive any communication from the assessee company nor the assessee submitted any financial details for the FY ending 31.03.2015 to its banker. The assessee provided item-wise details amounting to Rs.20.83 crores which was found to be far more than the value of sales and the closing stock. The assessee did not provide any details about utilization of these items for production or any other evidence to show that the value of these items had suddenly reduced to ‘nil’ even if the same was taken as scrap. The assessee failed to provide the basis of valuation of these items and simply categorized these items as obsolete. Even as per Tax Audit Report, no cost audit was performed. Furthermore, no remark was made regarding any exceptional item or extraordinary item in respective columns of the tax audit report and in the notes on account to the Balance Sheet. The assessee furnished a certificate from its partner and auditor without any input or certification by any technical expert. The Ld. AO, thus, concluded that entire exercise was done with the intention to reduce the profits. The facts in Alfa Laval (India) Ltd (supra) were stated to be different since in the present case, the assessee’s basis of valuation was ambiguous and no basis was given for its working. Secondly, the bank had clearly given contradictory report thereby casting serious doubts about the authenticity of assessee’s claim. Thirdly, the audit report was conspicuously silent on the crucial aspect of huge amount of “obsolete” stock.
In such a situation, Ld. AO was correct in disallowing the impugned claim of the assessee. Reference was made to the decision of Hyderabad Tribunal in Dr Reddy’s Laboratories Ltd. (174 Taxmann.com 238) to support the conclusion. The Ld. CIT(A) controverted the argument of the assessee by observing that during the period 2015 to 2020, there were many telecom companies operating both in India and abroad and thus, the contention that due to prevailing 2G spectrum situation at that time, the assessee could not get buyers to sell its items, was also not convincing. Finally, the view of Ld. AO in rejecting assessee’s claim was endorsed. Aggrieved, the assessee is in further appeal before us.
Our findings & Adjudication
5. We have carefully heard the rival submissions and perused the material available on record. The short question that falls for our consideration is whether Ld. AO was justified in substituting the assessee’s valuation of obsolete inventory by an assumed value when the assessee had valued the inventory in accordance with the recognised principle of lower of cost or net realizable value as prescribed by ICAI in Accounting Standard-2 (AS-2) dealing with valuation of inventories.
6. At the outset, it is important to appreciate that valuation of closing stock is not an exercise in determining the historical cost of inventory alone. The fundamental accounting principle is that inventory cannot be carried at a value higher than the amount expected to be realised from its sale or use. Thus, where inventory has become obsolete or commercially unusable, the relevant consideration is its actual net realizable value and not historical cost. The assessee’s claim cannot, therefore, be rejected merely because the original cost of the inventory was substantial. What is relevant is its market value at the end of the relevant previous year.
7. From the enumerated fact, it emerges is that the assessee has followed consistent method of accounting to value its stock over the years and the said method is in consonance with standard method of valuing the closing stock i.e., lower of cost price or net realizable value as prescribed by AS-2 of ICAI. There is no reporting by Tax Auditor that the stock has been devalued by the assessee rather audit report indicate the method of valuation of closing stock and no deviation in the same has been observed therein. The assessee’s business during this year suffered heavily due to adverse business conditions. The same is evident from the fact that its sales in AYs 2011-12 & 2012-13 was Rs.29.25 Crores & Rs.49.27 Crores which dramatically declined to Rs.7.82 Crores & Rs.3.09 Crores during AYs 2013-14 & 2014-15. The sales in this year are merely Rs.4.99 Crores. On the other hand, assessee’s closing stock has always remained in the range of more than Rs.50 Crores over AYs 2011-12 to 2014-15. The closing stock in this year has been valued at Rs.3.22 Crores and ultimately, the assessee is left with no stock in AY 2017-18. It is pertinent to note that closing stock of this year has been carried forward to next year. The assessment for AY 2016-17 has been completed by the department on 14.12.2018 u/s 143(3) wherein no objection has been raised on carry forward of closing stock of AY 2015-16 which was taken as opening stock for AY 2016-17. The opening stock of AY 2016-17 has been assessed by the department without drawing any adverse inference. In other words, the closing stock of this year has been accepted to be the opening stock of the next year. If the valuation claim is rejected in this year, the assessee’ opening stock for the very next year would increase to the extent of disallowance. The same would ultimately increase the business loss of the assessee in the next year. The whole exercise would, accordingly, be tax neutral only.
8. We further find that it is not the case of the department that the assessee has not maintained stock records. In fact, the assessee has maintained item-wise stock details and arrived at valuation of each of the items on the basis of lower of cost or net realizable value. This valuation method has consistently been followed and no technical opinion, as required by Ld. AO, is required to be taken since it is the management’s wisdom to value its stock in accordance with prescribed accounting standard which has been done in the present case. A certificate to that effect was already furnished by the assessee.
9. At this juncture, it would be useful to take note of decision of Hon’ble Bombay High Court in the case of Alfa Laval (India) Ltd. (133 Taxman 740). In that case also, the assessee wrote-off obsolete inventory which were not moving for the last three years in view of the change in designs or specifications due to its technological upgradation. The assessee valued the closing stock of obsolete items at 10% of cost. The Ld. AO held that the assessee neither furnished the list of obsolete items nor produced any records to show that the items were not moving. The Ld. AO accordingly, adopted realizable value of obsolete items at 50% of the cost. The Ld. CIT(A) deleted the addition on the ground that the actual realization of the obsolete items in the subsequent year was less than 10% of the cost. The Tribunal restored the view of Ld. AO. However, Hon’ble High Court held that the assessee furnished duly certified auditor’s report which clearly justified valuation of obsolete items at 10% of cost, the assessee was entitled to value the closing stock at market value or at cost whichever was lower. The value of the closing stock had been taken as the value of the opening stock in the subsequent year. The obsolete items were in fact sold in the subsequent year at a price less than 10% of the cost. Under such circumstances, it could not be said that the valuation of the obsolete items as done by the assessee and certified by the auditor was not proper or arbitrary. The Ld. AO, in fact, arbitrarily valued the obsolete items at 50% of the cost without disclosing the basis for such valuation. The Ld. AO did not doubt the correctness of certificate of the auditor regarding the valuation of obsolete items. Finally, the issue was decided in assessee’s favor. This decision has subsequently been affirmed by Hon’ble Supreme Court which is reported as 295 ITR 45. The crux of this decision is that where Ld. AO substituted a higher value without disclosing a cogent basis whereas the assessee, on the other hand, valued the obsolete inventory on the basis of the auditor’s report and the revenue had no material basis for adopting a different value, the assessee’s valuation could not be regarded as an arbitrary one. The Court specifically disapproved an assessment based upon an assumed realisable value which was unsupported by any material evidence on record. The principle emerging from the said judgment is not that every claim of obsolescence must mechanically be accepted or rejected rather it is that the revenue must have some cogent material before substituting its own valuation for a valuation made by the assessee in accordance with a recognised method of accounting. We find that the ratio of this decision squarely applies to the fact of the present case before us and Ld. CIT(A) has erred in distinguishing the same.
10. The case law of Dr Reddy’s Laboratories Ltd. (174 Taxmann.com 238), as referred to by Ld. CIT(A) is distinguishable on facts. In that case, the issue was of computation of book profit u/s 115JB(2). It was observed that the assessee claimed raw material consumed which include provision created for inventory obsolescence whereas the same was not added back in Book Profits. It was noted that the assessee valued inventory on the basis of lower of cost price or net realizable value. The said method itself takes care of reduction in the value of inventory. Therefore, there was no requirement of passing separate entry into the books of account under the head obsolescence of inventory. The separate provision of inventory was not in accordance with the Accounting Standard of ICAI for valuation of inventory. Since the assessee has reduced the value of inventory, it was nothing but a diminution in the value of asset which would fall under Explanation 1 to section 115JB and thus, needed to be added back to the Book Profits. This case law is thus clearly distinguishable and not at all applicable to the facts of the present case before us. Rather it reinforces the fact that the valuation of the inventory has to be done only on the basis of lower of cost price or net realizable value.
11. In the present case, the assessee has furnished substantially more than a bare assertion. There was physical verification of the stock by the management, item-wise details were furnished, the business line itself was discontinued, the stock was stated to have become old and non-moving, and the valuation was certified by the auditor. In the audited accounts, inventory valuation policy was disclosed and this method was consistently being followed by the assessee since nothing on record demonstrates change in method of valuation by the assessee. The fact that the bank account was classified as NPA also provides relevant corroborative circumstances regarding the severe deterioration in the assessee’s business position. We also find considerable force in the contention of the assessee that the AO has not undertaken any independent valuation exercise rather the claim has been rejected on mere presumption and assumptions. The Ld. AO has observed that the stock could not have zero value because some scrap value would necessarily be attached to it. However, this is only a presumption. The AO has not identified any particular items which allegedly had scrap value nor any such quantification have been done. No material has been brought on record to identify scrap value by comparing it with the prevailing market price of such scrap, nothing has been shown that any purchaser was willing to purchase the obsolete items, no comparable transaction has been shown nor any technical or valuation report establishing a positive net realizable value has been demonstrated by the revenue. Likewise, Ld. CIT(A) has not brought on record any material establishing the actual realizable value of the disputed inventory. In our considered view, the revenue cannot reject a valuation at ‘nil’ merely by observing that some scrap value “must” exist. If the revenue seeks to substitute a particular value, the substituted value must have some evidentiary foundation which is missing in the fact of the present case. The position is analogous to the principle recognised in Alfa Laval (India) Ltd. (supra) wherein the revenue’s estimate was found unsustainable because it was not supported by any disclosed basis. We are also of the considered opinion that valuation of the inventory has to be done in accordance with prescribed method of accounting and the method should be consistently followed by the assessee and both these conditions have been fulfilled by the assessee on the facts of present case before us. There is no statutory requirement that every valuation of obsolete inventory should necessarily be certified by any independent technical expert, which, condition has arbitrarily been imposed by lower authority. The only question to be considered is whether the assessee has reasonably demonstrated the basis of the valuation and whether the revenue has material to establish that the valuation is incorrect. In the facts of the present case, the assessee’s books of accounts were audited. The physical inventory was verified and certified by the management and the auditor. The assessee furnished item-wise details and explained the circumstances resulting in discontinuation of the relevant business. The valuation was made by applying the recognised accounting principle of lower of cost and net realizable value. Once these facts are placed on record, the burden shifts to the revenue to demonstrate, with some positive material, that the inventory had a higher realizable value. The mere fact that the certificate was not countersigned by a technical expert cannot convert an otherwise supported accounting valuation into an arbitrary claim.
12. So far as the reliance placed by the Ld. CIT(A) upon SBI’s letter stating that the bank had not received communication from the assessee regarding valuation of stock, is concerned, we find that the said fact, on standalone basis, do not controvert the otherwise valid claim of the assessee. There is no requirement that the valuation of stock should be done in consultation with the assessee’s banker. The question before us is the value of inventory as on 31.03.2015. Whether the assessee separately communicated its valuation to the bank is a collateral matter. The bank’s statement does not refute the claim of the assessee, in any manner and the said fact could not be pitied against an otherwise valid claim of the assessee. At best, the bank’s response creates a circumstance requiring examination; it does not constitute an independent valuation of the stock. Moreover, classification of the account as NPA is itself a circumstance consistent with the assessee’s contention that the relevant business had suffered serious commercial deterioration. It cannot, by itself, establish the precise value of the inventory, but neither can the absence of a separate communication to the bank establish that the inventory retained its book value.
13. The Ld. AO has also made out a case against the assessee by referring to the fact that as many as 96 items which were not appearing in the stock summary as compared with the earlier year. We find that this circumstance, without further enquiry, could not justify rejection of assessee’s claim. If the revenue entertained a doubt regarding disappearance, consumption, disposal or scrap realization of particular items, it was open to the AO to undertake item-wise verification. No such exercise appears to have been undertaken. The assessment has instead proceeded on a broad presumption that because certain items did not appear in the subsequent stock statement, the entire write-off was fictitious or profit-motivated. Such a conclusion is bereft of any positive material on record. Therefore, the said fact does not carry much weight given the valid explanation as furnished by the assessee on inventory valuation. In the present case, the assessee has demonstrated a specific commercial event i.e., the discontinuation of its telecom-related business and it has explained why the inventory lost its utility and marketability. The revenue, on the other hand, has not established an alternative realizable value. Accordingly, the revenue’s stand in rejecting in assessee’s claim could not be said to be justified on the peculiar facts before us.
14. The Ld. AO has also proceeded on the premise that the exercise was undertaken with the intention of reducing profits. We are unable to sustain such an inference in the absence of corroborative material supporting the same. A reduction in profit resulting from a genuine write-down of inventory is the natural consequence of applying the lower of cost or net realizable value principle. The mere magnitude of the write-down could not be the basis for concluding that it was fictitious. In fact, the magnitude of the write-off is itself explained by the exceptional circumstances of the assessee’s business. The assessee had a substantial opening inventory but only limited purchases and sales during the year and ultimately discontinued the relevant business. These facts are consistent with the assessee’s explanation that a large portion of the old inventory had ceased to have commercial utility.
15. We also note that the principle underlying inventory valuation is forward-looking to the extent that net realizable value represents the amount expected to be realised from sale in the ordinary course of business.The Hon’ble Bombay High Court in Alfa Laval (India) Ltd. (supra) placed considerable significance on subsequent realization of obsolete items as corroboration of the valuation adopted by the assessee. We find that assessee’s opening stock in the very next year stood accepted by the revenue as already elaborated by us in the preceding paragraphs.
16. Upon overall consideration of the facts and circumstances of the case, we would hold that the assessee has valued the inventory as per prescribed accounting standard, the method has consistently been followed by the assessee, the inventory was physically verified, the assessee furnished item-wise details, the assessee discontinued the relevant line of business due to adverse market conditions, the valuation was reflected in the audited accounts and supported by the auditor’s certification. The Ld. AO, on the other hand, did not conduct any independent valuation of the disputed stock, no comparable sale, market quotation, scrap valuation or other evidence was brought on record to establish a positive realizable value and the addition rests substantially upon the presumption that the inventory must have some value. As per the decision in Alfa Laval (India) Ltd. (supra), in the absence of a proper basis for substituting the assessee’s valuation, an arbitrary enhancement of the value of obsolete inventory could not be sustained.
17. We would, therefore, hold that lower authorities were not justified in rejecting the impugned claim of the assessee. We order so. The Ld. AO is directed to re-compute the income / loss of the assessee and the losses which is to be carried forward to the next year.
18. In the result, the appeal of the assessee is allowed.
Order pronounced on 10th September, 2026
