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25. In the Ground No. 1(d) the assessee has assailed the order of the CIT(A) on the ground that the CIT(A) has erred in holding that various expenses viz., telephone expenses, conveyance and vehicle expenses, travelling expenses and legal professional expenses are to be split in the ratio of turnover of both the plants viz. Food Division and Soya Division. During the course of assessment, the AO has noticed that the assessee had debited the major expenses towards the directors' remuneration, books, periodicals, Diwali expenses, professional charges, vehicle expenses, telephone and trunk call expenses, directors' travelling expenses, in Prestige Food Industries. Nominal expenses were debited in the account of Prestige Soya Industries. The assessee was asked to make the explanation of this disproportionate allocation of miscellaneous expenses. Being not satisfied with the explanation of the assessee, the AO bifurcated the expenditure and divided it in the ratio of the turnover of both the units of the assessee. Dissatisfied, the assessee appealed to the CIT(A) but did not find favour from him and the CIT(A) has reallocated the expenditure.

26. The learned counsel for the assessee submitted that the CIT(A) has not properly bifurcated the expenses incurred on telephone and trunk call, conveyance and vehicle expenses, travelling expenses, legal and professional expenses fee in both the units. He submitted that the Prestige Soya Industries is a manufacturing unit of the assessee and its maximum sale was made to Prestige Foods, the other unit of the assessee. In the sale from one unit to another, no expenses are required to be incurred. The maximum sale was made from the Prestige Foods to outsiders. The assessee has furnished a statement which is at p. 77 of the first compilation of the assessee whereby the assessee has calculated the ratio in which the expenditure incurred in both the units should be bifurcated. As per his statement, the total sale of the Prestige Industries during the financial year 1991-92 was at Rs. 61,90,88,427 out of which sale made to Prestige Soya Industries was at Rs. 32,45,32,245 and the sale to other than Prestige Food Units were at Rs. 29,45,56,182. The total sales of both the units in the financial year were at Rs. 1,09,79,15,023 out of which sales of Rs. 29,45,56,182 were made by Soya Industries to outsiders and sale of Rs. 80,33,58,841 were made by Prestige Food Units to outsiders. So, the expenditure should be bifurcated in the ratio of the sale made by both the units to the outsiders. According to the appellant, the calculation of ratio comes to 26.83 per cent for Soya Industries and 73.17 per cent for Prestige Food Units. The said criteria was not adopted either by the AO or the CIT(A). They have adopted the ratio to turnover of both the units.

27. In oppugnation, the learned Departmental Representative submitted that the criteria shown by the assessee is not a workable criteria which can be adopted in the multiple units of the assessee. The general criteria is to bifurcate the common expenditure amongst the units of the assessee in their turnover ratio. The learned Departmental Representative has put an example that in case the Prestige Soya Industries made the entire sales of its products to Prestige Food Industries, then there would be no sale to the outsiders. It means that as per the assessee's version, there should not be any expenditure to be borne by the Prestige Soya Industries, which is not possible. The management is common in both the units and whatever services were rendered by them, these were for both the units. No specific details or accounts were furnished before the AO or the CIT(A) to establish the fact that the particular expenditure was incurred for a particular unit.

28. We have heard the submissions of the rival parties and examined the orders of the authorities below. The disputed expenses pertain to the expenditure incurred on telephone, trunk call, conveyance and vehicle travelling expenses, legal and professional fees. There is no detail available on record to show that particular expenses were incurred for a particular unit. The contention of the Revenue cannot be overlooked that whatever expenses were incurred in these heads, these were incurred for both the units. The example given by the learned Departmental Representative that in case the Prestige Soya Industries does not make any sale other than to Prestige Foods, no expenses can be claimed against Soya Industries as per the contention of the assessee appears to be plausible and we are of the view that this model of apportionment of expenditure in both the units furnished by the assessee (sic-at) p. 77 of the first compilation of the assessee does not appear to be reasonable. Whatever expenses are incurred for multiple units, the total expenses should be bifurcated as per their turnover ratio in the absence of any specific evidence for specific expenditure for a particular unit. A similar formula was adopted by the AO and followed by the CIT(A). The CIT(A) has adjudicated this issue in detail and we do not find any error in its order pertaining to the issue. Accordingly, we uphold the order of the CIT(A) and reject the claim of the assessee.