JUDGMENT This appeal by Revenue challenges order passed by Incometax Appellate Tribunal, Bench at Pune, dated November 8, 2011. assessment year in question is 2005-06. Revenue's appeal before Tribunal raised two grounds. first ground was that Commissioner of Income-tax (Appeals) should not have deleted addition of Rs. 27,63,920 made by Assessing Officer under section 37(1) of Act from out of assessee's claim towards keyman insurance premium. second ground was that sum of Rs. 42,48,052 on account of under valuation of closing stock of shares and bonds was rightly added. Mr. Vimal Gupta, learned senior counsel, appearing in support of this appeal, submits that all four questions are formulated by Revenue are substantial questions of law. He submits that keyman insurance policy has been taken in case of present assessee, partnership firm. It is on life of two partners. partnership firm cannot have existence in law independent that of partners. Therefore, Assessing Officer was justified in estimating percentage, namely, 20 per cent. of keyman insurance premium. That was on basis that this insurance premium expenditure was personal in nature and of partners. It was not incurred wholly and solely for purpose of business of assessee's firm. Mr. Vimal Gupta would submit that both Commissioner and Tribunal erred in law in deleting this addition. Both having referred to no prohibition in making such estimation and, therefore, appeal deserves to be admitted. We have perused order of Commissioner and Income-tax Appellate Tribunal to extent relevant for us. With regard to keyman insurance premium, Tribunal held that it is admitted position that assessee is firm registered under Indian Partnership Act, 1932. It is engaged in business of purchase and sale of securities and investment in capital market. insurance premium was paid and expenditure of Rs. 1,38,19,600 under this keyman insurance premium was claimed on life of two partners. assessee explained that this expenditure was deductible under section 37(1) of Income-tax Act since it was incurred by firm to protect business from loss which may arise due to death of partner. beneficiary of insurance policy was firm itself and not individual partners. It was expenditure related to partners. Assessing Officer did not agree with this stand of assessee and on legal position proceeded to hold that keyman insurance premium could be treated as personal expenses of partners. He disallowed 20 per cent. of keyman insurance premium on basis that this expenditure was personal in nature of partners and it was not incurred wholly and solely for purpose of business of assessee-firm. Commissioner deleted such ad hoc disallowance and Tribunal has upheld that order of Commissioner. We have, in light of this admitted factual position perused findings. findings of Tribunal in paragraph 5 are that ad hoc deduction could not have been effected. More so, when Department itself has clarified that premium paid on keyman insurance premium is allowable as business expenditure. keyman insurance premium is life insurance taken by person on life of another person who is or was employee of first mentioned person or is or was connected in any manner whatsoever with business of first mentioned person. Commissioner referred to legal provisions. Commissioner rested his findings on factual position that emerged from record. record indicated that partnership firm comprised two partners. It was dealing in securities and shares. policy was obtained for benefit of firm inasmuch as firm's business would be adversely affected, in event, one of partners met with untimely death. It is, therefore, concluded by Tribunal that such being nature of expenses and business of firm being of dealing in securities for protecting it this policy was obtained. premium expenditure was incurred in above factual backdrop. There was no basis, therefore, for making any deduction or disallowance. disallowance was purely matter of conjecture and surmise on part of Assessing Officer. It is in these circumstances that Commissioner deleted this disallowance. That exercise of Commissioner having been upheld in peculiar factual backdrop, we are of opinion that any wider question or controversy does not arise for our consideration and determination. view taken been consistent with factual position is plausible and possible one. That does not raise any substantial question of law. Even in relation to other two questions, we have perused paragraph 9 of Tribunal's order. We find that when cost actually paid is considered, there is no concept of any notional valuation. average cost is worked out by considering total cost actually paid for purchasing shares and dividend by number of shares. Tribunal held that assessee's perception that value taken on basis of "weighted average method" is notional, is incorrect. Why it has to be termed as such, has been reasoned by Tribunal in paragraph 9. It has been held that assessee has been following this method of valuation of closing stock for last 16 years. In these circumstances, unless some distinguishing features were on record, Assessing Officer should not have interfered with this method of valuation, is finding which Tribunal renders. It concurs fully with finding of Commissioner when he holds that method of valuation or stock followed by assessee was accepted method and in consonance with law as well as Accounting Standards. We do not find that such finding of fact rendered by Tribunal can be termed as perverse. It is in consonance with factual materials placed on record. On this count as well this appeal is not raising any substantial question of law. As result of above discussion, appeal fails and it is, accordingly, dismissed. No costs. *** Commissioner of Income-tax v. Agarwal Enterprise