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2018 (12) TMI 1260 - ITAT AHMEDABADAddition on account of suppression of production - AO has made comparison of net profit ratio shown during the year under consideration at 1.64% with the net profit ratio of 1.77% shown in the immediate preceding year - Held that:- There cannot be a standardizations or uniformity of sugar consumption in these nature of products, and therefore method adopted by the AO to club all the products together and standarise consumption of sugar at a particular quantity is not correct method. The ld.CIT(A) has dealt with both the aspects viz. consumption of papaiya and sugar for different products manufactured by the assessee and arrived at a just conclusion that the approach of the AO in estimating the production was not correct. CIT(A) has recorded a finding that consumption of raw material varies from product to product, which passes through different stages. For determination of total production, all products and raw-material cannot be clubbed together to arrive at standard or a uniform quantity, because the assessee is manufacturing different products having different recipe with common raw-material. The ld.CIT(A) has appreciated the facts in right perspective and restricted the addition to ₹ 10,00,000/-. We do not find any infirmity in the order of the ld.CIT(A), which we confirm and reject the grounds of appeal of the Revenue.
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