side. We have gone through the past results
and find that the turnover of the assessee in assessment year ... find while turnover of the assessee is increasing
from year to year the GP rate is decreasing. It is also not understood
years ranging
from 37.64% to 43.04%. The AO observed that though the turnover of
the assessee declined by 17% vis-a-vis the preceding year ... relevant material on
record, it is noticed that though the turnover of the assessee decreased in
comparison with the preceding year, the Assessing Officer
such a
payment as excessive in view of decrease in the ratio of net profit to turnover.
He restricted the deduction to the amount
sale of
licensed products and was directly linked with the amount of
turnover.
29. Before us, Ld. Counsel relied upon catena of judgment wherein
similar ... would determine the extent of royalty to be paid and it
would decrease or increase every year depending upon the
decrease or increase
segment of the assessee was enhanced by about
127% whereas the overall turnover in manufacturing segment
had gone down by 50%. It was further submitted ... assessee incurred substantial losses due to
lower capacity utilization and a substantial decrease in its Sales.
26 ITA no. 1790, 1201/Del/2014
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
logic. The A.O. has lost
sight of the fact that the turnover of the appellant company has increased
multifold and by this logic also ... increased by 0.79%) during the year under
consideration. Had there been any decrease or loss resultant to the
increase of consumption, it would have been
computed by Ld. AO/TPO on
account of treatment of
decrease in stock as non-
operating in nature.
It was submitted that after incorporating correct ... certain filters like some companies are with
abnormally high margin and high turnover.
10 ITA no. 1153/Del/2014
(Element K India
Knorr Bremse India Pvt. Ltd., Faridabad vs Acit, Faridabad on 31 May, 2018
IN THE
Ge India Industrial (P) Ltd.,, Haryana vs The Acit.,Kheda Circle,, Nadiad on 4 December
