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Section 145 of the Income-tax Act, 1961 - Method of accounting - Valuation of stock - Assessment year 1991-92 - Whether average cost price of entire stock purchased in course of year can be taken as value of closing stock for determining value of closing stock at the end of year, but nonetheless it should be either average cost or actual cost and, it cannot be, in any way, in between - Held, yes - Assessee was carrying on business of manufacturing of rice from paddy and its sale - During course of assessment proceedings for assessment year 1991-92 assessee stated that valuation of closing stock had been taken at cost price - Assessing Officer did not accept value of closing stock of common paddy and fine paddy as shown by assessee and he adopted valuation of closing stock at rates given by Marketing Inspector, which resulted in an addition in closing stock - Tribunal held that assessee while taking closing stock at average cost price had also taken value of opening stock as on 1-4-1990 whereas normally opening stock being purchase for earlier year is utilized for manufacturing and it is inconceivable that opening stock was available at the end of year and, therefore, value of the opening stock cannot be taken even for purpose of determining average cost which had been done by assessee; Tribunal upheld order of Assessing Officer - Whether there was any infirmity in order of Tribunal - Held, no CASES REFERRED TO Chainrup Sampatram v. CIT [1953] 24 ITR 481 (SC) [Para 6], CIT v. A. Krishnaswami Mudaliar [1964] 53 ITR 122 (SC) [Para 7],CIT v. British Paints India Ltd. [1991] 188 ITR 44/ 54 Taxman 499 (SC) [Para 8] and United Commercial Bank v. CIT [1999] 240 ITR 355/ 106 Taxman 601 (SC) [Para 9]. S.D. Singh for the Appellant. Shambhoo Chopra for the Respondent. ORDER R.K. Agrawal, J. - In the present appeal, filed under section 260A of the Income-tax Act, 1961 (hereinafter referred to as the Act) the appellant allege that five substantial question of law arises out of the order dated 4th December, 2002 passed by the Income-tax Appellate Tribunal, Allahabad relating to the assessment year 1991-92. 2. Briefly stated the facts giving rise to the present Appeal are as…

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