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"23. I have carefully considered the
observations of the A O and the arguments of the
counsel for the appellant. The turnover of the
appellant during the previous year was R.8.89
crores and the fuel expenses were Rs.8,23,723/-.
This year, the turnover has decreased
substantially to 2.26 cores whereas the fuel
expenses have gone upto Rs.16,53,931/-. In fact,
the fuel expenses have increased eight times with
respect to turnover. The appellant has not
furnished any plausible explanation with
supporting evidence for phenomenal increase in
the fuel expenses before the A O nor has
furnished any supporting evidence by giving
calculation such as production in quantitative
term and the quantity of steam used per unit of
production and the quantity of fire woods used
per unit of production. In the absence of any
plausible explanation given by the appellant along
with supporting evidence for the substantial
increase in the fuel expenses, the disallowance
made by the A O is held to be very reasonable
and justified. The addition made by the A O is
upheld and this ground of appeal is rejected.