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Therefore it is the contention of the appellant that or around half of the turnover, the purchase price has increased more than the sale price. It is to be mentioned that the appellant has not given the quantum of turnover of either grey stone or brown stone where there is appreciable difference between the increase in purchase price and increase in sale price. In the absence of such turnover, it is difficult to ascertain the degrees in GP rate on account of difference between increase in purchase price vis a vis increase in sale price. Moreover with respect to 43.27% of the turnover, no reasons have been given for decrease in GP rate as compared to last year. It ITA 765/JP/2014 & CO 02/JP/2016_ DCIT Vs Asha Mandowara is to be mentioned that the GP rate in current year is 8.31% as against 19.35% in the preceding assessment year i.e. A.Y. 2007- 08(which has been upheld by the ITAT).

3.2.2 Taking all the factors into consideration viz -

(a) the past history of the appellant

(b) that the purchase price has increased more than the sale price for certain qualities of brown stone and grey stone, but the turnover of each individual quality cannot be ascertained due to non maintenance of stock book and

(c) no reasons have been given for decrease in GP rate with respect to 46.73% of total turnover. I am of the considered view that while there are justifiable reasons for a minor fall in GP rate, as compared to last year. The submission of the appellant does not give any reason for decrease in Gross Profit rate of 46.73% of the turnover. For the balance part of the turnover where reasons have been given, it is not possible to quantify the decrease in gross profit in the absence of stock book. In view of the above, the G.P. rate is estimated at 19.20% of the turnover which is slightly lower than the G.P. rate of the preceding Assessment Year. This will result a trading addition of Rs. 9,44,204 (19.2% of Rs. 10,66,63,644 - Rs. 1,95,35,216). Therefore the addition made by the AO of Rs. 76,74,679/- is restricted to Rs. 9,44,204/-.