IN THE HIGH COURT OF DELHI AT NEW DELHI 
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         ITA 1022/2006  
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 SRF LTD.                        ..... Appellant 
 Through 
 Mr.S.Ganesh, Sr.Advocate with 
 Mr.Satyen Sethi, Advocate 
 versus 
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 COMMISSIONER OF INCOME TAX DEL      ..... Respondent 
 Through 
 Mr.Sanjeev Sabharwal, Advocate 
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 CORAM: 
 HON'BLE MR. JUSTICE VIKRAMAJIT SEN 
 HON'BLE DR. JUSTICE S. MURALIDHAR 
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 O R D E R 
                             14.11.2006 
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 Heard. 
 Admit. 
 After hearing learned counsel for the parties, the following substantial 
 questions of law are framed for determination:- 
 (i)Whether on facts and circumstances of the case and in law, Tribunal was right 
 in upholding reopening of assessment under Section 148 of the Act for the reason 
 that excise duty embedded in closing stock did not include advance payment of 
 excise duty in PLA and as such, income chargeable to tax had escaped assessment? 
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 ITA 1022/2006                                          Page 1 of 2 
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 (ii) Whether advance excise duty in PLA, which was not relatable to stock of 
 finished goods, was includible in valuation of closing stock, particularly in 
 the light of Berger Paints India Ltd. vs. Commissioner of Income Tax, [2004] 266 
 ITR 99? 
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 Paper books be filed in accordance with High Court Rules. 
 List in due course. 
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 VIKRAMAJIT SEN, J 
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 S. MURALIDHAR, J 
 NOVEMBER 14, 2006 
 nj 
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 ITA 1022/2006                                          Page 2 of 2 
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 73 
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