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Showing contexts for: turnover decrease in M/S. Sanee Infrastructure Pvt. Ltd., ... vs The Pr Cit , Bhopal on 1 June, 2020Matching Fragments
27. Now we need to see that whether proper enquiry was conducted by the Ld. A.O with regard to reasons No. 1 & 2 and 4. Reasons No.1 & 2 are inter related which relates to "High ratio of refund to TDS and Low net profit or loss shown from large gross receipts" and the reason No.4 relates to "mismatch in amount paid to Sanee Infrastructure Pvt. Ltd percentage of decrease in turnover is not in consonance with the percentage of decrease in cost of material purchased. Percentage of cost of material purchased which was approximately 44.92% in Assessment Year 2013-14 has increased to 60% for Assessment Year 2014-15 but interestingly salary, wages expenses has come down from 7.5% of the turnover to 7%. Now once these figures were in front of Ld. A.O which is the main basis of reasons No. 1 & 2 the minimum required enquiry was towards examining decrease in turnover and the increase in cost of material consumption. The details of sales made in the preceding and current year and the details for increase in purchase cost were the bare minimum details which the Ld. A.O could have gone through to form an opinion. Merely accepting the few liner reply of the assessee cannot be held to be sufficient or minimum enquiry in case of such limited scrutiny. The enquiry conducted by the Ld. A.O in the instant case for reasons 1 & 2 cannot be termed as adequate enquiry. Rather looking to the reply given by the assessee which is not at all clear in itself, in our view the Ld. A.O has not conducted any enquiry with regard to reasons No. 1 & 2 relating to High ratio of refund of TDS and Low Net profit or loss shown for large gross receipts. Thus Ld. Sanee Infrastructure Pvt. Ltd assessee and gives the details of the relatives with the amount of payment and the nature of such expenditure in the format provided in Form 3CD. These details may help the Assessing Officer to examine the payment related persons if the case is selected for scrutiny. We can say that these details assist the Assessing Officer to frame a correct assessment and energy is saved to gather related information from the huge financial data maintained by the assessee. There is hardly any occasion that such payment to relatives is disallowed by the Tax Auditor in his report by way of qualification of Audit Report and the same amount is mentioned in the ITR. Since no disallowance is made by the Tax Auditor the details of payment made to the relatives is mentioned in Report but the amount in ITR is 'NIL' there occurs mismatch.