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Showing contexts for: turnover decrease in Pr. Commissioner Of Income Tax-7, Delhi vs Uk Paints India Pvt. Ltd. on 3 December, 2024Matching Fragments
6. The Assessee also provided a brief analysis of the income earned in comparison to the earlier years. It claimed that during the relevant year, the Assessee had received dividend income of ₹8.55 crores, as compared to ₹20.75 crores earned in the prior year. It also claimed that during the year in question, its turnover had increased to almost 40%, that is, from ₹18.67 crores in the previous year to ₹24.66 crores. Thus, whilst the increase in the turnover was around 40%, the exempt income had decreased by almost 60%.
"7. I have carefully considered appellant's submissions and observations of AO in impugned assessment order. To meets ends of justice, in totality of facts and circumstances that assessee has suo motto made disallowance of some of the expenses (Rs. 750,000), same is not found to be defective by AO, the investments made by assessee yields taxable income also, there is no adequate satisfaction of AO before invoking Rule 8D, assessee has emphatically stated all expenses debited in P&L account pertains to manufacturing activities, there is increase in business turnover by 40% and decrease in exempt income by 60% in comparison to last year, saga of errors is there in AO's calculation of rule 8D disallowance, and other factors as pointed, I hereby sustain the lump sum disallowance at Rs. 20,00,000 in totality. Thus, AO is directed to recompute the disallowance keeping the total disallowance u/s 14A read with rule 8D at Rs. 20,00,000 in which disallowance already made by assessee shall be reduced (Rs. 750,000). Rest of the addition is directed to be deleted. In view of the above discussion, grounds No. 4 is partly allowed."