record. At the outset, we note that the assessee
has declared its turnover in the subsequent assessment year 2014-15 at
rupees 13.87 crores ... year under consideration. Generally, when the turnover
of the assessee increases than the margin decreases, it is because it is
assumed that the assessee
ratio for the last three A.Ys is as under:
AY. Turnover G.P. rate N.P. rate
(Rs.)
G.P. (Rs.) G.P. rate ... turnover has exceeded by 3 times
compared to A. Y.2006-07. This is one of the reasons that when
turnover increases profit ratio decreases
admitted fact that there was a tremendous increase in the
turnover of the assessee which increased from Rs. 5 Crore in the earlier
year ... earlier year, the increase in
the turnover may be a reason for slight decrease in the gross profit rate.
In the present case, the Assessing
simply stated that the G.P. ratio is decreased due to decline in sales
turnover and increase in purchase cost of raw material
increase of turnover and manufacturing activities as
against job work charges and due to flood gross profit has marginally
decreased. However, ld. Assessing Officer ... ignored some important facts which needs consideration in
adjudicating this issue:-
(1) Turnover of the assessee has more than doubled in Asst. Year
turnover,
therefore, no addition can be made without any adverse material / evidence
available on record. It is further submitted that assessee's turnover ... fact that due to worldwide recession the price had fallen coupled with decrease
in the exchange rate of US Dollars which has also affected
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
products, even the sale
price decreased in comparison to the preceding year. Moreover, the
appellant's turnover increased from 11.60 crores
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
further
argued that the sales turnover had increased by 14.18% but the
manufacturing sales had in fact decreased by 4.94% as the appellant had
begun
