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
account.
The AO observed that while the decrease in the turnover was
18.82%, the gross profit has fallen down to 46.69% which is
not justifiable
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
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
Increase in turnover in period 09/11 to 30/12-
Financial Year Period Total Turnover ... turnover for the period 9-11 to 30-12 was
Rs. 24,10,695 as against Rs. 29,93,487/-. At the outset, we submit
M/S Honeywell Technology Solutions Lab ... vs Joint Commissioner Of Income Tax ... on 26 August
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 ... 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
