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" On page 11 of the assessment order, the assessing officer has picked up 4 cases where the turnover has ranged from Rs.8.13 crores to Rs.23.62 crores. The G.P. disclosed varies from 5.50 to 9.1%. The appellant's turnover is Rs.14,76,68,868/-. There is a trend of decrease in G.P. as turnover goes up. Thus the fair estimation of G.P. in the present case would be between 5.50% to 9.1%. It is seen from the table that M/s. R. Vipul & Co. has shown a G.P. of 9% on a turnover of Rs.8.24 Crores while Gem Star Co. has shown a G.P. rate of 7.85% on a turnover of 18.42%. But since the appellant's turnover is 14.76 Crore, the assessing officer should have estimated between 7.85% to 9.1%. But assessing officer has also quoted another instance where M/s Parvati Gems has shown a G.P. of 5.50% on a turnover of 8.13%. I have also came across a case of Ruch Exports where a G.P. of 7.56% has been shown on a turnover of Rs.11.16 Crores. By adopting estimate at 5.20% in appellant's case an addition of 4% has been made, which to my mind is most reasonable. Ideally the appellant should have been given an opportunity to show cause as why the addition on account of comparative G.P. rates be not be made, which in this case has not been done. But, since assessing officer has taken lower than the minimum G.P. rates disclosed bymentioned parties-the grievance does not survive effectively. Even on merit the GP dislosed by the appellant @1.20% is too low to be left uninterfered with and requires upward rationalization which has been done by the assessing officer most reasonably. The assessing officer's action stands upheld."