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6. The next issue is with regard to estimation of net
profit at 1.30%. The appellant has admitted a net
income of Rs.14,44,347 at 0.29% of turnover. However,
the net profit admitted for A.Y 2010-11 is 1.30%. On
comparison with similar cases and also in view of the
appellant's trade results for A.Y 2010-11, the AO felt
the profit admitted by the appellant for the year under
question as very low. Accordingly, he estimated the net
profit at 1.30% and made an addition of Rs.49,03,130.
On this issue the appellant has submitted that edibile
oil business is highly volatile business and the profit in
the later years is due to introduction of new capital by
the partners, reduction in interest expenses and
investment in plant and machinery which resulted in
higher production. I have gone through the submissions
made by the appellant and found no force in the
argument of the appellant. As observed by theao, if
there is increase in the turnover in the subsequent year,
the ratio of profit would decrease. With the introduction
of new plant and machinery, the expenditure in the
following year must be high and due to the depreciation
claimed on the new machinery, the profit would reduce.
Hence, the appellant's argument is not correct. Further,
even though edible oil business is a highly volatile
business, the market conditions prevailed in a
particular year are one and same for all the traders and
hence this is not a factor which drastically reduces the
appellant's profit when compared to others. In view of
ITA No.1182 of 2014 Siddhi Vegetable Oil Products
this I am in agreement with the findings AO and the
addition made on this count is sustained".