place of
15.82% declared by assessee on the gross turnover of
Rs.1,69,62,197/-. Accordingly addition of Rs.7,09,229/- was made ... deleted on the basis of
observation that there was no substantial decrease in GP vis-à-vis
average of last three years GP calculated
assessment order is as under:
4. Deduction u/ s 10B
4.1. Export Turnover:
The export realization details furnished by the assessee shows that
the realized ... decrease in exchange fluctuation on the bill amount is only a
subsequent accrual after the completion of the transaction. The
increase/decrease in exchange fluctuation
alone ought to be considered, as the company fails the upper
turnover filter for FYs 2013-14 and 2014-15. (Ground No. 4.6 and
Additional ... turnover/service revenue while selecting the companies comparable to
the Assessee. In this regard, it is submitted that application of turnover
filter is a relevant
operating margins of
Access India Advisors Ltd. and there was short decrease in margins for the
succeeding years, which established that the assessment year ... assessee
that in the succeeding years, the margins have decreased i.e. in assessment
year 2009-10, it was 6.62% and in assessment year
turnover was Rs.106,66,34,514/-.
The G.P. was 0.51% and net profit was at 0.02% whereas the assessee
declared his turnover ... immediate preceding year. The AO asked the assessee for the
reasons for decrease in profit margin rate. The assessee could not offer any
satisfactory explanation
value at end of August,
2013 and only around 0.7% of the turnover of the financial
year ending March31, 2013. This cannot be termed ... small increase of 0.10 paise and on September 4,
2013 it decreased of Rs.0.30 paise. Thus, the disclosure of
the information
fall by 1.89%. The AO disallowed 0.50%
decrease in gross profit ratio of sales accordingly a disallowance of Rs.
29,65,305/- was made ... Workshop (Net) 3011895 4073408 3779046
Incentive (Net) 3496887 5527666 5167690
Turnover (A) 494087805 361680522 602007751
Gross Profit (C) 7739549 15484843 14362690
GP Ratio
that
turnover of the assessee in the assessment year under
appeal is higher as compared to earlier year, but, there is a
substantial decrease
from its investments in developing the value of
a trademark from its turnover and market share where it has a long-term
contract of sole distribution ... additional
return from the owner of the trademark, perhaps through a decrease in the
purchase price of the product or a reduction in royalty rate
figure of unaccounted turnover. Learned A. R. further submitted that figure
in the audited account for recorded turnover was supported by VAT returns
also ... Officer had applied a gross profit
rate of 3.7% on the unaccounted turnover which he calculated at
Rs.1,18,69,27,609/- The said