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wise quantities purchased and sold, the corresponding purchase and sale rates, and the closing stock balances. A perusal of the said statements, according to the AR, clearly showed that in F.Y. 2016-17 the average rate of sale had consistently decreased, notwithstanding the higher turnover in terms of volume.

4.5 In support of the above submissions, the learned AR placed reliance on the decision of the Hon'ble Gujarat High Court in the case of Commissioner of Income-tax-IV v. Symphony Comfort System Ltd. [(2013) 35 taxmann.com 533 (Guj.)]. In that case, the Assessing Officer had made an addition to the income of the assessee on account of fall in gross profit rate as compared to the preceding year, without pointing out any specific defect in the books of account or in the method of accounting followed by the assessee. Both the Commissioner of Income Tax (Appeals) and the Tribunal had deleted the addition, and the Hon'ble High Court upheld their orders.