comparison with earlier assessment year, but
such decrease is mainly due to decrease in turnover of the appellant company.
The appellant has not proved that
rate
was prejudicially decrease in the present year but the turnover has increased
and therefore, the same was rightly accepted by the CIT(A). Hence
operating assets) but at a
decreasing rate. Hence, it is appropriate to apply upper turnover
filter based on the classification of companies
fixing GP% at 7% by taking cue from the part of
turnover (of earlier part of the year) of 5.1% is not sustainable ... years, including relevant financial year) is as under:-
Total Turnover 250758982 736968737 2595778118
Increase/Decrease in -59959722 50871881 23178182
Stock
Total 190799260 787840618 2618956300
Expenses
against 91 % in the immediately preceding year. Thus, there appeared an abnormal
decrease in the yield of finished products during the year under consideration ... copper scrap in the lesser turnover where as in the current year
on the increased turnover it has purchased lower copper scrap of 11.65 lakh
observed that the turnover for the year under consideration
has increased from the previous years, however the GP rate
has decreased from the preceding previous ... further submitted that in normal
circumstances GP rate is inversely related to turnover, i.e. increase in
turnover usually results in lower GP rate
last year. In appellate proceedings AR has not
filed proper justification for decrease in G.P. rate to 4.64% however I find that
GP rate ... higher side, GP rate of 20% of declared
turnover is applied. Assessee gets resultant relief. This ground of appeal is
partly allowed."
Ground
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
upper limit on the
turnover/service revenue while selecting the companies
comparable to the assessee and that application of turnover
filter is a relevant criteria ... increase in the size and scale of the operations leads to a
decrease in the long run average cost of each unit or each
service
turnover filter at the lower limit
erred in not applying the said filter at the upper end so as to
reject high turnover companies. (Ground ... upper limit on the turnover/service revenue while selecting the
companies comparable to the assessee and that application of turnover
filter is a relevant criteria
