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Showing contexts for: turnover decrease in Mahavir Dye Chem, Surat vs Department Of Income Tax on 26 June, 2012Matching Fragments
5. We have considered rival submissions, perused the material on record and have gone through the orders of authorities below and the Tribunal decision cited by the Ld. A.R. of the assessee. In the present case, finding of Ld. CIT(A) is as per para 5, 5.1 & 5.2 of his order, which are reproduced below for the sake of ready reference:
"I have carefully considered both the positions. From the copies of the written submissions submitted before the AO, I find that voluminous details furnished as stated in the preceding paragraphs, along with the complete set of books of accounts,, vouchers and bills. The substance of the assessee's explanation regarding the fail in the GP ratio was that, while the of purchase, especially of raw-materials, had increased substantially, the selling price of the finished products did not increase in .proportion. It had in fact decreased in the comparison to the immediately preceding year. The AO discounted such explanation since, the purchase cost of some of the items had fallen. What she failed to appreciate was that, the purchase cost of the major items had increased in leading to an overall increase in the total purchase cost",, not only as a percentage of the turnover but also in comparison to the cost of raw-materials in the immediately preceding year. The increase in cost and the decrease in the selling price (which the AO apparently accepted), had led to the fall in the turnover by Rs.3.11 crores which was a decrease of 42.52%, 5.1 Instead of appreciating the facts of the case and the ground level situation, the AO sought details which not only the Assessee but any businessperson in the same business would not normally maintain. She sought the composition of the product mix with the input and output ratios of the current year in comparison to the two preceding years. She also sought to compare the manufacturing expenses of the current year with the preceding year, and observed that there was a 'saving' of Rs.11.20 lacs which was in fact a decrease in the expenses during the year; but she failed to take into consideration the decrease in the turnover as we!!. She repeatedly observed that the Assessee had conveniently escaped from furnishing such details including batch-wise details of production. The point to note is that, no businessperson can be expected to maintain his records as per the whims and fancies of the AO. The Assessee had maintained his records as per the prescribed accounting standards and the records were duly audited, and the Auditors had certified the correctness of such records.