TaxTMI 
TaxTMI 
2015 (1) TMI 1393
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.... the business of gold and silver, making of ornaments as well as selling bullions. The assessee filed its return of income on 25-09-2009 declaring NIL income. The Assessing Officer completed the assessment u/s. 143(3) vide order dated 26-02-2011 determining the total income at Rs. 8,76,65,079/- by making the following additions: 2.1 Subsequently, the Assessing Officer vide order dated 29-12-2011 passed u/s. 154 of the I.T. Act determined the revised total income at Rs. 73,40,88,070/- by making the following addition which was omitted to be added in the original assessment order although discussed in the body of the assessment order and disallowed. 2.2 Subsequently, in yet another order passed u/s. 154 of the I.T. Act on 23-01-2012 the Assessing Officer determined the total income at Rs. 73,42,67,410/- by making the following rectification: 2.3 The assessee filed an appeal before the Ld. CIT(A) who gave part relief to the assessee. So far as addition made to the trading account is concerned, the Ld. CIT(A) directed the Assessing Officer to estimate the profit by adopting the GP rate of 5.71% on turnover of Rs. 5,65,51,47,570/- thereby sustaining the addition of Rs. 21,49,93....
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....ts to the sister concerns when in reality, the A.O. in those cases had made additions to the profits shown by them in their hands. 2.3] The Ld. CIT(A) failed to appreciate that-- a. There were no defects in the accounts warranting rejection thereof. Even in the past years, the books were accepted by the Dept. b. All the transactions of purchases and sales with the sister concerns were genuine and they were not made for diverting profits of the appellant to the sister concerns. c. All the concerns had duly accounted for the sale and purchase transactions in the group and the same were duly accounted for VAT on the transactions effected. d. The transactions were executed with the sister concerns at the market rates only and even otherwise, there was no reason to warrant a conclusion that the appellant must have sold the stocks to the sister concerns at lesser price than the market value. e. There were substantial purchases of ornaments and bullion from the sister concerns which were acquired for trading by the appellant and hence the profit margin thereon was low. There were many transactions of purchases by the appellant from the....
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....uestion of making a disallowance u/s. 14A could not arise. d. The business exigencies required the appellant to invest in the shares of the group companies and thus, no disallowance of interest is warranted U/s 36 or Sec. 14A of the Act. 3.4] Without prejudice, the learned CIT(A) erred in making excessive disallowance of interest by considering high interest bearing loans were utilized for investment in the shares, when it was not so and considering the investments at the end of the year instead of properly considering the dates of various investments. 4] Property Income of Rs. 3,15,102/- 4.1] The learned CIT(A) erred in making following additions-- a. Disallowance of electricity expenses for the use for partner's residence -Rs. 81,906/- (para 31). b. Additional Disallowance of the telephone expenses - Rs. 38,012/- (Para 31.1). c. Additional electricity and telephone expenses - Rs. 1,95,184/- (para 31.2) 4.2] The learned CIT(A) failed to appreciate that the appellant on its own had made the disallowances for the use of the above assets for personal purposes in the return and the basis adopted was the same a....
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....wance u/s. 14A and hence, no separate disallowance was required. 8] Addition on account of differences in creditors' balances - Rs. 67,690/- 8.1] The learned CIT(A) failed to appreciate that the appellant had offered the above difference to tax in the next year and hence no addition was required in this year. 9] Interest to partner - Rs. 18,92,421/- 9.1] The learned CIT(A) erred in disallowing interest of Rs. 18,92,421/- paid to partner when the interest was paid to him in terms of partnership deed and the same was allowable as per the provisions of Sec. 40(b) of the Act. 9.2] The learned CIT(A) failed to appreciate that there was no device, much less colorable device to evade tax. 9.3] The learned CIT(A) did not appreciate the facts of the case and consequently erred in applying the provisions of sec. 40(A)(2)(b) with respect to interest paid to partner which was in accordance with law. 9.4] The learned CIT(A) failed to appreciate that the quantum of interest paid by the partner to the parties from whom he had received gold had nothing to do with the appellant's claim for deduction u/s. 40(b) of the Act. ....
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....e Ld. CIT(A) has erred in upholding the addition separately made u/s. 14A read with Rule 8D of Rs. 4,53,72,146/- as per the Note on Page No. 96 of the CIT(A)'s Order.". 4. Grounds of appeal No. 1(a) and 2 by the assessee and grounds of appeal No. 1 to 3 by the Revenue relate to the part relief given by the Ld. CIT(A) out of the addition made by the Assessing Officer. 4.1 Facts of the case, in brief, are that during the assessment proceedings the Assessing Officer observed that the comparative position of trading result of the assessee is as under: 4.2 From the above, he noted that on a total turnover of Rs. 955.78 crores, the assessee has declared gross profit @ 1.13% and net profit @ 0.9%. He analysed the comparative position of GP and NP of the other group concerns, the details of which are as under: He, therefore, asked the assessee to furnish the various details as per notice issued u/s. 142(1) to which the assessee replied. 4.3 From the various details furnished by the assessee the Assessing Officer noted that the assessee firm sold gold ornaments to sisters concerns at lower price than sold to other parties by Rs. 40.36/gram. He noted from the various detai....
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....essee to substantiate with evidence the details of melting gain on account of method followed by the assessee for purchase of gold ornaments from unregistered dealers. From the details furnished by the assessee, he observed that the percentage of melting gain is fluctuating between 1.30% to 14.54%. From the various details furnished by the assessee, he observed that there is only one solitary instance of 1.30% of melting gain and another solitary instance of 14.54% melting gain whereas in the maximum number of occasions melting gain have been more than 9% to 10%. However, the assessee has shown melting gain at 7.83%. Rejecting the various explanations given by the assessee, the Assessing Officer estimated melting gain at 10% of the gold issued weighing 259088.002 grams which comes to 25908.800 grams as against melting gain shown at 20288.186 grams. Accordingly, he held that gold weighing 5620.6014 grams has been suppressed and the assessee got manufactured new ornaments itself that are sold outside the books of account. The average rate/gram from the quantitative details of sales comes to 1510.50/gram. By applying the same rate, the Assessing Officer held that the assessee had earn....
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.... price of bullion and ornaments, vis-a-vis average purchase price paid to the third parties he arrived at the conclusion that all concerns except Rajmal Lakhichand Jewellers Pvt. Ltd., have paid higher average price for 10 gm of bullion to the sister concerns, vis-a-vis the purchases from third parties and similarly Rajmal Lakhichand Gold Pvt. Ltd., and R.L. Private Ltd., paid much higher price for ornaments, vis-a-vis the purchases from the third parties. In nutshell he observed that the sale and purchase with the sister concerns were not at par with the price charged to third parties. After analysing the various details furnished by the assessee relating to itself as well as of the various group concerns he prepared a consolidated trading account of all the concerns which show sale of Rs. 2219.54 crores while the sales actually made to the third parties are only Rs. 679.66 crores. Further, he also compared the purchase price paid to the sister concerns for bullion, vis-a-vis market price as per Mumbai bullion Association and noted that the assessee has paid higher purchase price of Rs. 3,10,10,720/- to the sister concerns. Similarly, he compared the purchase of ornaments from the....
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....3,482/- will take care of the addition made by the Assessing Officer on account of sales/purchases from sister concerns and melting gains. This would also take care of excess price paid on purchase of bullion and ornaments from sister concerns which was shown earlier to the tune of Rs. 3.10 crores and 15.21 crores respectively when compared with Bombay bullion exchange rates. 5.2 Aggrieved with such order of CIT(A) the assessee as well as the Revenue are in appeal before us. 6. The Ld. Counsel for the assessee strongly objected to the order of the CIT(A). He submitted that all the sister concerns of the assessee are based in Jalgaon. The assessee has from time to time made purchases of bullion from the sister concerns except in a few cases where it has purchased from outside parties. He submitted that like the stock market, during a day, the gold prices fluctuate and daily closing rates of Mumbai Bullion are published in the papers. The AO compared the rates paid by the assessee, vis-a-vis the Bombay rates and held that the assessee has paid the excess price to the sister concerns and accordingly invoked the provisions of section 40A(2) for making the addition. He submitted t....
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....ted that there are only two transactions for purchases from third parties during the year which show that the rate paid to them was the market rate. Therefore, when there are only 2 transactions during the year, their average worked out to a very low level, i.e. the average price paid to the sister concerns. Therefore, this basis is also not justified for judging as to whether the purchase price paid by the assessee to the sister concerns was the market price or not. He submitted that the assessee has conclusively shown that the price paid to the sister concerns was the prevalent market rates and it was not excessive and therefore the disallowance u/s. 40A(2) is not justified. 6.3 Referring to the copy of the assessment order of the group concerns placed at paper book 254 to 364 of paper book No. 1, he submitted that in other concerns the AO has invoked the provisions of section 40A(2) to hold that it has paid excess price to the other concerns for purchases. Referring to the assessment order of M/s. Manvi Holding Pvt. Ltd., placed at paper book page 274 he submitted that this is contradictory to the stand taken in the assessee's case, because on one side in the hands of the....
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....purchase of new ornaments to sister concerns is grossly incorrect. 6.6 He submitted that the A.O/CIT(A) have compared the rate paid to the sister concerns vis-a-vis the rates paid for the old ornaments to third parties. In respect of the old ornaments, the rates are bound to be lower because the same are not readily saleable and have to be melted and from the pure gold obtained after melting, the new ornaments are manufactured through karagirs and labour charges are required to be paid to the karagirs for manufacturing the ornaments. This is the business of all the jewellers to purchase old ornaments (mod) at a lower rate and after converting them into new ornament sale at a higher rate. This only will bring profit to any jeweller. Therefore the purchase rates of old ornaments are much lower. So far as the new ornaments are concerned, they are made on the instruction of the assessee from bullion or gold given to the karigars. 6.7 He submitted that the A.O./CIT(A) has again compared the rates of the new ornaments by considering the Bombay Bullion rates. He reiterated that basically Bombay Bullion rates should not be adopted for comparison of purchases and the yardstick should ....
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....fferent from what is estimated by the assessee at the time of purchase. 6.11 Referring to page 369 of paper book 2 he drew the attention of the Bench to the chart of the melting gain over the last three years and submitted that the melting gain for this year is comparable and little more than the earlier two years in which the melting gain was accepted. The very basis of the decision of CIT(A) and the A.O. is wrong. They have rejected the assessee's version without any evidence or proof. There is no fixed percentage of melting gain which can be visualized in the old ornaments. Such gain depends upon the gold content in the old ornaments. That cannot be computed exactly while purchasing the old ornaments where each item is different from the other. Whatever is obtained as melting gain, is accounted for by the assessee. He submitted that the assessee has maintained proper records. Therefore, the addition on this basis is also not justified. 6.12 The Ld. Counsel for the assessee submitted that the assessee has maintained the books of accounts which are closed and supported by balance sheet. All sales and purchases are vouched and the purchases are made through banking channe....
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....and that is also one major reason for fall in GP as these are not real trading transactions. However, the sister concerns have also maintained proper accounts and their quantitative trading accounts are given on pages 365 to 368 of the Paper Book 2. On all such sales and purchases VAT has been paid and the A.O. also has assessed the profits shown by the sister concerns in their hands. Their asst. orders are placed in the Paper Book 1 on pages 254 to 364. In view of these facts, there is no justification to estimate profits of the assessee which the CIT(A) has given. 6.16 He submitted that the assessee has not siphoned off the profits to the sister concerns. The CIT(A) has estimated 25% of purchases and sales with the sister concerns as genuine and further, he has estimated the G.P. of 5.71%. Accordingly, he has calculated G.P. @ 5.71% on estimated turnover of Rs. 5,65,51,47,670/- and arrived at Rs. 32,29,08,931/- as against the G.P. of Rs. 10,79,15,449/- and made an addition of Rs. 21,49,93,482/-. He submitted that in view of the facts and circumstances mentioned above, there is no justification for rejecting the books of accounts and for estimating the G.P. 6.17 He submitted....
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.... the assessee. We have also considered the various decisions cited before us. In this case, the assessee firm is one of the concerns of Rajmal Lakhichand group of cases in Jalgaon. The assessee firm is the oldest firm which was established more than 150 years ago. The assessee is engaged in the business of manufacturing and trading in gold, bullion, jewellery and ornaments. The AO completed the assessment of the assessee firm u/s. 143(3) of the I.T. Act. In this case, admittedly there is no survey or search action and the entire assessment is based only on the data provided during the course of the normal scrutiny proceedings. There are 2 major issues, i.e. (1) rejection of books of account as the AO resorted to the provisions of section 145(3) of the Act and (2) very high pitch additions made by the AO on the alleged purchases of the bullion and ornaments by giving higher prices as compared with the prices prevailing at the Mumbai bullion market and the addition towards alleged selling of bullion and ornaments to its sister concerns below the rate prevailing in the market thereby siphoning off the profits of the assessee firm to the intra group companies and more particularly to M....
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....ourse of assessment proceedings, sought information from the assessee on different issues. The AO asked the assessee in respect of the stock statement furnished to the bank for availing of the CC limit as on 31-03-2009 and it was found that the last stock statement furnished by the assessee was for 20-02-2009. On that basis, the AO came to the conclusion that it was a deliberate act on the part of the assessee for not furnishing the stock statement to the bank. During the course of assessment proceedings, the AO sought the explanation of the bank also. According to the AO, where there is a stock audit, the bank is bound to carry out the stock audit on the last date of the financial year or atleast thereafter immediately. The assessee has filed the details giving the cash credit facility from the Jalgaon Peoples Cooperative Society Ltd., against the hypothecation of the stock and debtors. On this aspect the AO concluded that the book results are not reliable. The AO has also given another reason that the assessee failed to file reconciliation of the stock statement in respect of the sales made on 31-03-2009. The AO has also reservation as the assessee could not prove conclusively th....
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....to independently determine the GP of the assessee. The AO also questioned the genuineness of the purchase of gold as well as the octroi payment. The AO has given the example of one of the group concern M/s. Rajmal Lakhichand Jewellery Pvt. Ltd. stating that the said concern was purchasing the gold from SBI but it was also noticed that the said company has also purchased gold from Brink's Arya India Pvt. Ltd. to the extent of 13 kg gold bars. In the opinion of the AO, when the assessee purchases gold from bank it is not understood as to how the gold has been purchased from the above company. 8.5 We find the AO made addition of Rs. 64,64,22,989/- by invoking the provisions of section 40A(2)(b) of the Act for alleged business of gold and ornament from its group companies or sister concerns by giving them higher price as compared to the prices declared by the Mumbai Bullion Association. Similarly, the AO also made addition of Rs. 12,01,53,323/- for alleged sale to the sister concerns of the ornaments and the bullion at a price which are allegedly lesser as compared to the rates declared by the Mumbai Bullion Association. 8.6 Para 10 is the only paragraph in the assessment ord....
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....he details of total sales (Annexure-1) and details of the total purchases (Annexure-2) which are as under. 8.8 The AO also made addition towards the melting gain and the reasons given by the AO for making the said addition are as under: "17. Melting Gain- As discussed above, the assessee has not properly maintained record which can be put to test about correctness of the claimed melting gain, shown melting gain at 7.83% cannot be accepted to be depicting the correct picture of the melting gain. The above enclosed chart on close scrutiny shows that melting gain shown at 1.30% is solitary instance, so also melting gain shown at 14.54% is also only once, whereas, in the maximum number of occasions, melting gain have been more than 9% to 10%. Therefore, the melting gain is estimated at 10% of the issued gold weighing 259088.002 grams which comes at 25908.800 grams as against shown gain at 20288.186 grams. Accordingly, the gold weighing 5620.6014 grams has been suppressed and the assessee got manufactured the new ornaments out of that and sold outside the books of accounts. The average rate per gram as per the quantitative details on sale comes to Rs. 1510.50 per gram, By ap....
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....ns of the group operate from the same address i.e. 169, Balaji Peth, Jalgaon. Of the 6 concerns engaged in the business of gold, only 2 concerns namely Rajmal Lakhichand (Appellant) and M/s. Rajmal Lakhichand Jewellers(P) Ltd. (RLJPL). have outlets for direct sale to customers. While the assessee has showroom at Jalgaon, M/s. RLJPL has showrooms at Nashik and Thane. He noted that the assessee firm's purchases of bullion and ornament from the sister concerns amounts to Rs. 873.60 crore i.e. 93.67% of total purchases. Remaining 6.32% purchases are made from other parties including bank. The assessee firm has shown to have purchased bullion worth Rs. 419.87 crore from sister concerns representing 99.30% of total bullion purchased. The assessee has purchased only 25kg bullion valuing Rs. 2.91 crore from other parties. Similarly, the assessee has purchased new ornaments worth Rs. 453.72 crore from the sister concerns representing 88.99% of the total ornament purchases. The assessee firm has purchased old ornaments (mod) worth Rs. 56.10 crore from third parties. As regards sale of bullion, the assessee firm has sold bullion worth Rs. 122.90 crore representing 27.7% of total sales of ....
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....e ornaments in the entire group and has observed that the groups average sale price of ornaments to third parties is Rs. 13,726/10 gms as against Rs. 13,410/10 gms to the intra group transactions. The Ld. CIT(A) therefore observed that prima-facie it appears that while purchase of the bullion and ornaments from sister concerns were made at higher rate, sale of ornaments to sister concerns was made at a lower rate as compared to the sale of ornaments to third parties. 8.15 To understand the controversy we reproduce here the comparative chart showing the average prices towards the purchase of the ornaments and bullion (para 10 of CIT(A)'s order): 8.16 As observed by the Ld. CIT(A) all the above concerns of the group, except M/s. Rajmal Lakhichand Jewellers Pvt. Ltd. has paid higher average price/gm of bullion to sister concerns, vis-a-vis purchases from the third parties. He has further observed that in respect of the ornaments while Rajmal Lakhichand and sons, Manvi Holdings Pvt. Ltd. R.L. Gold Pvt. Ltd., and Rajmal Lakhichand Jewellers Pvt. Ltd., did not purchase ornaments from third parties, R.L. Gold Pvt. Ltd. and Rajmal Lakhichand Jewellers Pvt. Ltd. are paid higher pr....
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....This closing stock does not include gold received under CDS or from Pune concern. There was roughly net availability of 5kg of gold under GDS. Thus the total availability of gold ornaments and bullion was approx at 4559.2kg with the entire group. However, total sales of bullion and ornaments is shown at 16415.77kg (Bullion at 7423.29kg and Ornaments at 8992.48kg). The position of trading of bullion and gold that emerges in respect of RL group as a whole is as follows: i) Total purchases of bullion and gold(kg) from 3rd parties : 4624.36 kg Add: a) Opening stock : 365.89 kg b) Gold under GDS : 5.00 kg ii) Total availability of Bullion and ornaments : 4995.26 kg iii) Closing stock : 436.00 kg iv) Bullion and ornaments available for sale (ii)-(iii) : 4559.23 kg v) Total sale of bullion and jewellery shown by the group : 16415.77 kg After recording the above facts and figures the Ld. CIT(A) concluded that the entire group has shown inflated turnover in the form of fictitious purchases and fictitious sales in the name of the sister concerns. He also observed that the bullion and ornaments to the ext....
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....ompared to the average price of the ornaments sold to unrelated parties/third parties, the Ld. CIT(A) has observed that the assessee has charged an average price of Rs. 13,350/10 gms from sister concerns as against the average price of Rs. 13,906/10 gms charged from other parties for sale of gold ornaments. As noted by the Ld. CIT(A) the difference in the average sale price worked out to Rs. 55.60/gm as against Rs. 40.96/gm taken by the AO in the assessment order. The Ld. CIT(A) has also observed that although there is no provision in the Income Tax unlike section 40A(2)(b) which is in respect of the expenditure but the said aspect also cannot be ignored which has affected the gross profit and suggest that books of account do not depict the correct picture. 8.19 in respect of the melting gain addition of Rs. 84,89,937/-, the Ld. CIT(A) has observed that the assessee has purchased gold ornaments weighing 436.56 kg mainly comprising of MOD (old ornaments) from the third parties and assessee has shown the melting gain in respect of 259.08 kg only. The rest was used as bullion or new ornaments. The assessee filed the chart showing the gross weight of the ornaments, net weight of the....
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....eep increase in the turnover of the assessee firm from Rs. 82.55 crores in A.Y. 2007-08 to Rs. 955.78 crores in A.Y. 2009-10 and the said inflated turnover comprise major part of the transactions with the intra group companies. As per the explanation of the assessee, the transactions in the other companies were inflated to get the bank finance as the assessee was having limited CC limit. It is also seen that assessee has sold ornaments to M/s. Manraj Jewellers Pvt. Ltd. on 30-03-2009 to the extent of Rs. 24.41 crores and purchased ornaments to the extent of Rs. 20.47 crores on 31-03-2009 The said Manraj Jewellers Pvt. Ltd. has no showroom but has shown the purchase of 959.66kg of ornament at market value of Rs. 127.42 crores from the sister concerns. The Ld. CIT(A) has also brought most of the data, facts and figures to show as to how the assessee as well as other group companies in the Lakhichand Jewellers group are involved in inflating the turnover by showing only paper transactions of sale and purchases of bullion as well as ornaments. Even it is also strange to note that in the case of Manraj Jewellers Pvt. Ltd. and other few entities they do not have any showroom, but they ha....
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....9,11,365] will be fair and reasonable and realistic. He worked out total GP taking rate 5.71% on the sales turnover of Rs. 565.51 crores and worked out the GP at Rs. 32,29,08,931/- which according to the CIT(A) is the reasonable and fair GP and he reduced the GP declared by the assessee from the said figure of Rs. 10,79,15,449/-. He finally sustained addition of Rs. 21,49,93,482/- as against total addition of Rs. 77,50,76,249/- made by the Assessing Officer, i.e. on account of purchases from the sister concerns Rs. 64,64,22,989/-, diversion of profit to sister concerns Rs. 12,01,63,323/- and melting gain of Rs. 84,89,937/-. 8.24 in the present case, the entire GP addition is based on the local market rate of the bullion in Jalgaon and Mumbai market rate which are given by the Mumbai Bullion Association. In the present case, the commodity is gold and both the authorities below have worked out the average price of the bullion as well as the ornaments/gm for making the comparison of the market rate in Jalgaon and market rate in Mumbai. There is no dispute about the fact that there are lot of intra group transactions in respect of the bullion as well as the ornaments. As per the rec....
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..... Hence, prima-facie the proposition are applicable. There is no dispute about this legal position but the core question is whether the assessee has paid excess price than the market rate to the related parties or to the sister concerns for the purchase of the bullion (99.50-standard gold). As per the argument of the Ld. Counsel for the assessee, even if there is a marginal difference in the market price of the Mumbai and the Jalgaon but that prices are covered in the transportation and delivery. The assessee has filed a chart at pages 42 to 55 of paper book No. 1 in which assessee has given names of the sister concerns, gold weight, rate paid, total value, sales, Jalgaon rate on the same day and the Mumbai rate. As per the said chart on 09-04-2008 for the standard gold- (99.50), the assessee has paid Rs. 12400/10 gms when the Jalgaon rate was Rs. 11805/10 gms. Hence, there is a difference of Rs. 595/-. So assessee has made excess payment. The assessee has also given examples on 03-05-2008 and 06-05-2008, as per the chart compared to the even local market the assessee has made the payment in excess of the local market rates. Immediately thereafter assessee has given the sample exam....
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....e. The argument of the Ld. Counsel for the assessee is that it was done to facilitate to obtain the finance. It is pertinent to note here that assessee has filed the chart showing the loans availed by the assessee and other group concerns, which is placed at pages 711 to 714 of the paper book. The assessee was enjoying the CC limit of Rs. 5.56 crores. At the same time, the other group concerns/sister concerns were enjoying the CC limit of Rs. 52.81 crores. The assessee has also filed a letter dated 25-04-2008 of the SBI (page 712 of paper book) in which one of the group concerns M/s. R.L. Gold Pvt. Ltd. has obtained a gold loan under the domestic jewellery industry scheme from the SBI to the extent of 30 kg. It also supports the case of the assessee that with the meager cash credit limit of Rs. 5 crore the assessee by no stretch of imagination can reach to the turnover of Rs. 955 crore. As per the statistics given by the Ld. CIT(A) in his order, it is seen that there is high frequency of transactions between the assessee and intra group entities. Even in some of the cases bullion is purchased and sold either on the same date or immediately on the next day. If the assessee has not e....
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....g account prepared by the Ld. CIT(A) as the total turnover of the assessee is shown at Rs. 1065.32 crores when the same is actually 955.78 crores. Same way, the transactions with the third parties including bullion and gold are to the extent of Rs. 435.37 crores but as per the trading account prepared by the Ld. CIT(A) the same is shown as Rs. 679.66 crores. Hence, prima-facie there are mistakes in the recasted trading account and the same cannot be put to test. 8.31 The next area of the transactions is gold ornaments. Admittedly, the assessee is also manufacturing and selling gold ornaments. The assessee is also engaged in buying gold ornaments and after refining the same, said gold is used in the manufacturing of the jewellery. There are intra entity transactions of the ornaments by the assessee as well as transactions with the third party. As per the chart attached to the assessment order, the total sale of the ornaments to sister concerns is to the extent of Rs. 397.45 crores and to the third parties Rs. 110.89 crores. As per the statistics given in the impugned order, it is seen that the assessee has sold the ornaments to the sister concerns and immediately on the next day ....
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....ents. Moreover, there may be variation in the labour charges also. Hence, we do not agree with the average price formula adopted by both the authorities below for making the addition of Rs. 12,01,63,323/- on alleged selling of the ornaments to the sister concerns at lower price than the price charged to the unrelated parties. 8.33 We also find that the trading account prepared by the Ld. CIT(A) (page 58 of his order which has already been reproduced at para 5 of the impugned order) also includes direct income (MTF gain). As per the chart placed before us, we find that the assessee firm is not involved in the marginal trading and forwarding contracts. But at the same time other intra group entities, i.e. R.L. Gold Pvt. Ltd. Rajmal Lakhichand Jewellers Pvt. Ltd., Manraj Jewellers Pvt. Ltd., R.L. Gold Pvt. Ltd. have declared substantial amount of MTF gain and the same is included in the gross profit of the respective concerns. We fail to understand when the assessee firm is not involved nor has earned any MTF gain, then how the Ld. CIT(A) has included the MTF gain of Rs. 25,50,87,766/. The assessee has filed the copy of the audited statement of account in the compilation and the pr....
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....separate addition on the reason that the addition sustained towards purchase of the bullion at higher price and diversion of the profit will cover the estimated melting gain. The AO has observed that the assessee has shown melting gain of 7.83% which was not acceptable to the AO. He adopted 10% on estimate basis as melting gain and addition was made in respect of the difference to the income of the assessee. As noted by the AO on the gross gold (MOD) old ornaments weighing 259088 gms assessee had shown gain at 20288.186 gms which is average 7.83%. The AO worked out the gain at 25908 gms which is at 10% of the gross weight of the old ornaments given to the refinery and accordingly made addition by holding that the assessee has suppressed the melting gain to the extent of 5620.60 gms. The AO adopted the average price/gm at Rs. 1510.50 and accordingly made addition of Rs. 84,89,937/-. The Ld. CIT(A) confirmed the addition. 8.37 The contention of the assessee is that records are maintained by the assessee firm in respect of the ornaments given for refining. However, if the karigars have not maintained the record the assessee cannot be held responsible for that. Another plank of argu....
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.... incurred an expenditure of Rs. 16,30,963/- on the running and maintenance of Generator as against Rs. 5,11,074/- and Rs. 5,99,972/- respectively incurred in the preceding 2 years. Out of the above amount, the Assessing Officer treated Rs. 1 lakh towards residential portion and rest Rs. 15,30,963/- towards business purposes for self and for sister concerns. Since the assessee has not recovered any amount from the sister concerns, the Assessing Officer disallowed 50% of the same presuming that it should have been recovered by the assessee from sister concerns. Thus, the Assessing Officer made addition of Rs. 1 lakh plus Rs. 7,65,481/-, i.e. Rs. 8,65,481/-. 9.2 In appeal the Ld. CIT(A) reduced the above disallowance from 50% to 15% of the total expenditure incurred on Generator expenses by observing as under: "33. The AO had disallowed Rs. 8,65,481/- vide para 19 of his order. However, it was not added back while computing the total income. Later, the error was rectified vide an order Dt. 23/01/2012 u/s. 154 of the Act. Facts of the case reveal that ground floor and 2nd floor were used by group concerns and partners respectively. Tenants are paying rent which according to....
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....wance to 15% of the total expenses of Rs. 16,30,963/-, which in our opinion, is reasonable under the facts and circumstances of the case and does not call for any interference. Accordingly, the above grounds by the assessee are dismissed. 10. Grounds of appeal No. 1(f) and 6 to 6.2 by the assessee relate to disallowance of interest on loan to R.K. Oswal Graphics Pvt. Ltd., amounting to Rs. 3 lakhs. 10.1 Facts of the case, in brief, are that the Assessing Officer during the course of assessment proceedings noted that the assessee has advanced a sum of Rs. 25 lakhs to R.K. Oswal Graphics Pvt. Ltd., on 29-09-2008 and no interest has been charged. On being questioned by the Assessing Officer, it was submitted that the assessee had advanced a sum of Rs. 25 lakhs to R.K. Oswal Graphics Pvt. Ltd., for the purpose of printing calendars, however, the transaction did not materialise and the balance remained outstanding. Considering the trading nature of the advance given, the assessee has not charged any interest to the said party. However, in subsequent years it has charged 12% per annum to the said party. However, the Assessing Officer was not satisfied with the explanation given by ....
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....sequent years. However, for the impugned year, we find no justification on the part of the revenue to force the assessee to charge interest on such trade advance. In this view of the matter, we set-aside the order of the Ld. CIT(A) and direct the Assessing Officer to delete the addition. 11. Grounds of appeal No. 1(g) and 7 to 7.2 by the assessee relates to disallowance of interest amounting to Rs. 7,51,171/-. 11.1 Facts of the case, in brief, are that the Assessing Officer during the course of assessment proceedings noted that the assessee has invested the business funds towards construction of guest house. The opening balance was Rs. 93,07,328/- and the closing balance was Rs. 1,57,31,726/-. On being questioned by the Assessing Officer, it was submitted that the expenditure was incurred for constructing the guest house and not for expansion of existing business or starting any new business and therefore were not capitalised. Therefore, the provisions of section 36(1)(iii) will not apply. However, the Assessing Officer was not satisfied with the explanation given by the assessee. He held that if the borrowed funds were not utilised for construction of the guest house the fir....
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.... to 9.4 by the assessee relate to disallowance of interest to partners amounting to Rs. 18,92,421/-. 12.1 Facts of the case, in brief, are that the Assessing Officer during the course of assessment proceedings observed that the assessee firm has paid interest on GDS to partner Shri Ishwarlal I. Lalwani at Rs. 45,31,460/- whereas Ishwarlal has paid interest to gold depositors at Rs. 26,39,039/-. He observed that the partner does not deal with gold ornaments business in his individual capacity. It is the firm which deals with gold ornaments business. The firm and Ishwarlal Lalwani obtained the gold from the public on same terms and conditions and pay interest on same rate but certain gold is accepted in the partner's account by the staff of the firm and then the partner gives it to the firm on higher rate and in this way the firm pays more interest to the partner. According to the Assessing Officer, if the same gold was directly routed through the firm, the firm would have paid only Rs. 26,39,039/-. Thus, firm has paid more interest to the partner than required in the garb of capital brought in by the partner in the firm as GDS. On being questioned by the Assessing Officer, it....
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.... practices, i.e. paying interest @9% on the prevailing value of gold to the partner and paying interest @9-16.5% on quarterly basis on a fixed value of Rs. 2,750 per 10gm to other depositors. Looking the matter from this angle, in my opinion, the AO is justified in disallowing the excess interest of Rs. 18,92,421/- applying the provisions of Sec. 40A(2)(b) of the Act. The disallowance of Rs. 18,92,421/- out of interest paid to the partner is accordingly, confirmed". 12.3 Aggrieved with such order of the CIT(A) the assessee is in appeal before us. 12.4 The Ld. Counsel for the assessee strongly opposed the order of the CIT(A). He submitted that as far as the firm and partner are concerned, the interest on the capital contributed by the partner is governed by section 40(b) of the Act which provides that simple interest upto 12% per annum on the capital contributed by the partner will be allowed as deduction while computing the income of the firm. Whether the capital is out of own funds of the partners or is borrowed by the partner has got nothing to do with the rate at which interest is allowable to the partner u/s. 40A(b). Since the assessee firm had paid interest @9% p.a. to o....
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....ission of the Ld. Counsel for the assessee that the firm would have paid higher amount of bank interest by getting that much quantity of gold than it paid to the partner on account of such quantity of gold. 12.7 We find merit in the above submission of the Ld. Counsel for the assessee. There is no bar for the partner to obtain the gold under the gold deposit scheme which was simultaneously done by the assessee firm also. As long as the interest paid to the partner on such gold under the gold deposit scheme is within the permissible limit, there should not be any disallowance. Since in the instant case the firm has paid interest @9% on the gold deposited by the partner obtained from the customers under the gold deposit scheme account, therefore, it is immaterial as to at what rate of interest the partner has paid to the customers. In this view of the matter, we set-aside the order of the CIT(A) on this issue and direct the Assessing Officer to delete the addition. This ground by the assessee is accordingly allowed. 13. Grounds of appeal No. 1(j) and 10 to 12 by the assessee relate to denial of depreciation on windmill amounting to Rs. 31,133/-. 13.1 Facts of the case, in br....
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....ith a direction to recompute the depreciation on windmill in the light of the direction of the Tribunal for A.Y. 2008-09. We hold and direct accordingly. This ground by the assessee is accordingly allowed for statistical purposes. 14. Grounds of appeal No. 1(b) and 1(c) and 3 to 3.4 by the Assessee and grounds of appeal No. 1 by the Revenue relate to the disallowance u/s. 14A and 36(1)(iii) of the I.T. Act. 14.1 Facts of the case, in brief, are that the Assessing Officer during the course of assessment proceedings observed that the assessee has invested Rs. 42.75 crores towards share application money in Rajmal Lakhichand Jewellers Pvt. Ltd., out of which opening balance was Rs. 28 crores and during the year further amount of Rs. 14.77 crores was invested. He observed that the assessee is not only utilising the business funds of the firm but also utilising the services of the employees, electricity, telephone, furniture, computer, stationery etc. for making the entries in books of account. Thus, business funds and services of the drivers are used for business purpose for taxable income and investment in shares which will yield dividend income and which is exempt u/s. 10(38) o....
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..... Sundry creditors amounting to Rs. 196.95 crore include M/s. Manraj Jewellers (P) Ltd. (Rs. 60.83 crore); Manvi Holdings (P) Ltd. (Rs. 4.94 crore); R L Gold (P) Ltd. (Rs. 50.26); R L & Sons (Rs. 17.70 crore) and RLJPL (Rs. 61.96 crore). This according to Ld. CIT(A) shows clearly that the firm has used borrowed funds for making investment in the group companies. The firm has also accepted the fact that borrowed funds have been used for investment in shares of its closely held group companies. The firm is paying interest on the above mentioned funds including sundry creditors. The appellant according to Ld. CIT(A) has also made loans and advances to the tune of Rs. 97.53 crore. The appellant has paid total interest amounting to Rs. 12.52 crore and received an interest of Rs. 6.44 crore. The appellant has failed to prove that the said investment was made for business expediency. All the group companies in which investments have been made are closely held companies, by and large controlled by Shri. Ishwar S. Lalwani who is also a partner in the appellant firm (40% share in profit/loss). The appellant is engaged in trading of bullion/ornaments and making such investment is not an integ....
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....he following additional ground: "1] Assuming without admitting that the interest of Rs. 4,82,82,028/- is disallowable u/s. 36(1)(iii) as the borrowings are utilised for investment in shares of the group companies, the learned CIT(A) failed to appreciate that-- a. The above interest is allowable as a deduction under the head 'income from other sources' and even though, there is no dividend received from these companies, the interest is allowable in view of Supreme Court decision in [115 ITR 519]. b. The allowance of this interest would result in the loss under the head 'income from other sources' and the same ought to have been set off against income from business u/s. 71. c. Accordingly, there is no addition required of the above amount to the total income of the assessee. The assessee submits that the additional ground raised is legal in nature and as all the facts are on record, the assessee requests for admission of the above ground." 14.6 The Ld. Counsel for the assessee submitted that the additional ground is legal in nature and all the facts are also on record. Relying on the decisions of the Hon'ble Supreme ....
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.... assessee has increased substantially over the period of last 3 years. Therefore, this investment is made for business purposes only, therefore, disallowance is not justified. 14.10 in his alternate contention, he submitted that since the assessee had substantial non-interest bearing funds in the form of capital and the sundry creditors which exceeds the amounts of investment in the sister concerns, therefore, following the decision of the Hon'ble Bombay High Court in the case of CIT v. Reliance Utilities and Power Ltd., reported in 313 ITR 340 no disallowance of interest is called for. In his yet another alternate contention the Ld. Counsel for the assessee submitted that the interest income is to be allowed as deduction under the head "income from other sources" as the share investment in the group concerns would yield dividend income which is taxable under this head. Now in this year although there is no dividend income, interest is allowable as deduction under this head in view of the decision of the Hon'ble Supreme Court in the case of CIT v. Rajendra Prasad Moody reported in 45 ITR 519. Accordingly, to the extent of interest, i.e. Rs. 4,82,82,028/- there would be l....
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....d the various decisions relied on by both the sides. The assessee in the additional grounds has claimed that the interest income is to be allowed as a deduction under the head "income from other sources" as the share investments in the group concerns would yield dividend income which is taxable under this head. According to the Ld. Counsel for the assessee although no dividend income has been received during the year, however, such interest is allowable as a deduction and therefore there will be loss to the extent of Rs. 4,82,82,028/- which can be set off against business income during the year u/s. 71 of the I.T. Act. However, this alternate contention as per the additional grounds of appeal was not examined by the lower authorities since the assessee has raised this issue for the first time before the Tribunal as additional grounds and the lower authorities had no benefit of deciding the issue from this angle. Therefore, we in the interest of justice deem it proper to restore this issue to the file of the Assessing Officer for fresh adjudication. The Assessing Officer shall decide the issue as per fact and law after giving due opportunity of being heard to the assessee. We hold a....
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....Rs. 4,72,800/-. Therefore, the difference is Rs. 4,56,244/-. Similarly, in absence of any rent received from partners he determined the rental income of the residential portion at Rs. 6,96,183/-. Thus, the gross total income was determined by the Assessing Officer at Rs. 16,24,427/-. After deducting the municipal tax and 30% deduction u/s. 24, he determined the income from house property at Rs. 10,46,392/-. After deducting the rental income disclosed by the assessee at Rs. 2,40,254/- the Assessing Officer made addition of Rs. 8,06,138/-. Thus, he made a total addition of Rs. 15,76,669/- (Rs. 1,19,918 + 6,50,613 + 8,06,139). Original addition was Rs. 22,62,889/- which was subsequently rectified to Rs. 15,76,669/-. 15.2 In appeal the Ld. CIT(A) deleted some of the additions like alleged rent of Rs. 8,06,138/- and reduced the disallowance on account of use of telephone and electricity by tenants from 50% made by the Assessing Officer to 15% and determined the disallowance on account of personal use of partners of 15% of the telephone and electricity charges as determined by the Assessing Officer. The relevant observation of the Ld. CIT(A) reads as under: "31. The facts rev....
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....re many other personal and business consideration for not letting out the premises to an outsider especially when partners themselves are residing in the building. The AO has not brought on record any material in support of this addition. I am therefore of the opinion that there is no justification for the said addition which is hereby deleted. In short out of the aggregate addition of Rs. 15,76,669/-, the disallowances of Rs. 3,15,102 (Rs. 81,906 + Rs. 38,012+ Rs. 1,95,184) are confirmed, while the addition of Rs. 12.61.567/- (Rs. 4,56,429 + Rs. 8,06,138) is deleted." 15.3 Aggrieved with such order of the CIT(A) the Assessee as well as the Revenue are in appeal before us. 15.4 The Ld. Counsel for the assessee strongly challenged the order of the CIT(A) on this issue. He submitted that without any basis or reasons the expenses towards personal use are estimated at 15% and the additions have been made. He submitted that no such disallowance was made in earlier assessments. The rent charged to the sister concern was inclusive of all and therefore the question of any disallowance of expenses does not arise. He accordingly submitted that the disallowance being on the higher side ....
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....e Revenue and Ground of appeal No. 1(h) and 8.1 by the assessee relate to part relief given by the Ld. CIT(A) out of addition on account of difference in trade creditors. 16.1 Facts of the case, in brief, are that the assessee during the course of assessment proceedings noted that there is difference in the closing balance of two creditors namely, Sunny foresight Pvt. Ltd., Mumbai Rs. 42,847/- and Harmony Multi Media Pvt. Ltd., Surat Rs. 67,690/-. On being questioned by the AO, the assessee submitted that the balance due by the assessee to Sunny foresight Pvt. Ltd., as on 31-03-2009 was Rs. 1,12,273/- whereas the dues shown by the assessee was Rs. 1,55,120/-. It was submitted that during F.Y. 2009-10 the entire dues has been cleared by account payee cheque. The dues were cleared on 28-07-2009. So far as Harmony Multi Media Pvt. Ltd., Surat is concerned, it was explained that the difference was due to a bill of Rs. 67,690/- recorded twice. It was argued that the error has been rectified in the F.Y. 2009-10 by reversal of the entry. However, the Assessing Officer did not agree and made addition of Rs. 1,10,537/- on the ground that the payment during subsequent year and reversal of....
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.... by any of the provisions of section 38(2). Further, salary to driver being fixed such expenditure remains same whether the vehicle is used for personal purpose or not. The provisions of section 38(2) relied upon by the Assessing Officer according to the Ld. CIT(A) also supports the contention of the assessee. He accordingly deleted the disallowance of Rs. 32,086/- out of driver's salary on the ground that the same is not in accordance with law. The Ld. Departmental Representative could not point out any mistake in the above finding of the Ld. CIT(A). In view of the above, we find no infirmity in the order of the Ld. CIT(A). Accordingly, same is upheld and the ground raised by the Revenue on this issue is dismissed. 18. Ground of appeal No. 6 by the Revenue reads as under: "6. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition made on account of Depreciation on vehicles of Rs. 8,14,855/- ". 18.1 Facts of the case, in brief, are that out of total depreciation on vehicles amounting to Rs. 24,44,656/- the assessee suo moto disallowed 1/3rd of depreciation amounting to Rs. 8,14,885/- and claimed depreciation of....
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.... Accordingly, the same is upheld and the ground raised by the Revenue is dismissed. 19. Ground of appeal No. 7 by the Revenue reads as under: "7. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition of Rs. 1,44,856/- on account of disallowance of interest under GDS." 19.1 Facts of the case, in brief, are that the Assessing Officer during the course of assessment proceedings observed that a sum of Rs. 1,44,856/- being post dated cheques issued by the assessee to the depositors under GDS are outstanding since 1998 to 30-03-2008. On being questioned by the Assessing Officer, it was submitted that it has not been cleared upto 15-12-2011 nor any fresh cheques have been issued to them. On being further questioned by the Assessing Officer, it was explained as under: "As already stated, we issue post dated cheques to the depositors under GDS. In case if cheques become time barred, we revalidate the same when the depositor approaches us. However, in case of few parties cheques are neither presented nor the parties have approached us for revalidation, for the reasons not known to us. We are of course bound to make....
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....efore explanation 1 to Sec. 41(1) is also not applicable to the facts in question. Considering the facts of the case and the judicial decisions, I am of the opinion that the addition of Rs. 1,44,856/- u/s. 41(1) has no merit and the same is deleted." 19.5 Aggrieved with such order of the Ld. CIT(A) the Revenue is in appeal before us. 19.6 After hearing both the sides, we find no infirmity in the order of the CIT(A) deleting the addition. Admittedly, the assessee has not written off the liability entries in its books of account and the same continues to appear in the balance sheet. Merely because the liability was old, the same cannot be a ground for making addition so long as there was no cessation of liability by writing back the same. Various decisions relied on by the Ld. CIT(A) also supports the case of the assessee. In view of the above and in view of the detailed reasoning given by the Ld. CIT(A) on this issue and in absence of any distinguishable features brought to our notice by the Ld. Departmental Representative, we find no infirmity in the same. Accordingly, same is upheld and the ground raised by the Revenue is dismissed. 20. Ground of appeal No. 8 by the Reven....
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....tion by observing as under: "46. The GDS introduced by the appellant firm is in operation since 1993. It has been brought to my notice that so far there is no complaint from any of the depositors regarding the non receipt of gold either on maturity or at anytime thereafter irrespective of the time that might have passed after the date of maturity. The appellant has also placed on record copies of relevant receipts etc. in respect of all depositors including 50 depositors to whom letters are stated to have not been served. Again as per the regular practice the appellant issues post dated cheques to the depositors against interest. It is claimed that such cheques are duly encashed and none of them has been dishonored or bounced back. I have perused the records and find that there are large number of depositors from different area and that the scheme is in operation since last more than 18/19 years. Again the genuineness of the scheme has been verified several times and no addition on this score is ever made in the past assessments completed u/s. 143(3) of the Act. In fact, in few of the cases gold has already been returned/renewed. The appellant has filed the necessary detai....
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....ame. Accordingly, same is upheld and the ground raised by the revenue is dismissed. 21. Grounds of appeal No. 9 by the revenue relates to the order of the CIT(A) in deleting addition of Rs. 1,32,772/- on account of bogus liability. 21.1 Facts of the case, in brief, are that the Assessing Officer during the course of assessment proceedings sent notice u/s. 133(6) to various parties. However, no reply was received from Mr. Ghulabchand M. Rajur of Ahmedabad. The assessee furnished the copy of the ledger for F.Y. 2009-10 according to which the payment has been shown in cash on different dates below Rs. 20,000/- each from 08-04-2009 to 13-07-2009 and Rs. 12,772/0 has been shown as outstanding as on 31-03-2010. Since no evidence of receipt of payment by Ghulabchand Rajuria was produced, the Assessing Officer doubted the genuineness of the payment made in F.Y. 2009-10. How and who gave the payment has also not been produced by the assessee before the Assessing Officer. The Assessing Officer noted that although the party is in Ahmedabad and assessee is at Jalgaon, however, no travelling expenses was debited on these dates for Ahmedabad and no cash has gone from Jalgaon to Ahmedabad. ....
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....CIT(A) passed the order the assessee moved a rectification petition u/s. 154 before him stating that there are certain errors while working out the GP ratio which should have been 4.67% as against 5.71% determined by him. Similarly, the assessee also submitted that the sales to third parties was Rs. 6,69,79,16,774/- and not Rs. 679,66,42,775/- as considered by the Ld. CIT(A). However, the Ld. CIT(A) held that there is no mistake apparent from record as far as GP rate of 5.71% has been considered by him. It was estimated by him after rejecting the assessee's books of account u/s. 145(3) of the I.T. Act and various exercises were undertaken by him to arrive at fair estimate of income. In view of the above, he rejected the 154 petition filed before him. 22.1 Aggrieved with such order of the CIT(A) the assessee is in appeal before us with the following grounds: "The Grounds of Appeal stated below are WITHOUT PREJUDICE to each other. 1. The learned CIT(A) erred in rejecting appellant's application u/s. 154 of the Act. On the facts and in the circumstances of the case, the CIT(A) be directed to rectify the mistake which is apparent from the face of r....
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.....1,61,06,612/- Rs, 1,32,772/- Rs. 1,60,335/- Rs.2,57,16,912/- Rs.22,18,26,288/- as per return Rs. 3,04,447/- Rs.23,52,42,879/- Less: Depreciation as worked out by The assessee after considering the Appeal effect to be given For A.Yr. 2008-09 as per CIT(A)'s order Rs.2,56,85,779/- Less: Unabsorbed depreciation loss: A.Yr. 2006-07 Rs. 69,44,206/- Rs.2,77,56,261/- A.Yrs.2007-08 A.Yr.2008-09 Assessed Income Rs.8,71,91,554/- Rs.12,18,92,021/- Rs.8,76,65,079/- Document 2 Purchases made from sister concerns u/s.40A(2)(5) as per para 10 page 44 of the assessment order passed on 26-12-2011 : Rs.64,64,22,989/- Document 3 (a) on account of disallowance out of Generator maintenance expenses : Less Excess addition in property income: Rs.8,65,481/- Rs.6,86,140/- Document 4 A.Y. Turnover Gross profit Rate of Net profit Rate of GP NP 2009-10 9557881767 2008-09 3041859685 107915450 1.13% 67478528 2.22% 9099920 3469506 0.11% 0.09% 2007-08 825500879 31311929 3.79% 6671486 0.81% Document 5 M/s.Rajmal Lakhichand Jewellers Pvt. Ltd. A.Y....
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....adevi I. Lalwani 30% 2. Shri. Manish I. Lalwani 40% 3. Smt. Ruchi A. Lalwani 30% 3. Shri. Ishwarlal S. Lalwani 40% 4. Shri. Amrish I. Lalwani 30% 5. Smt. Neetika M. Lalwani 30% Document 10 Bullion gold Sister concern 1313.82 From Others 1166.10 The difference of Rs.147.76/- per gram over the quantity of 31,95,845.50 grams works out at Rs.47,22,18,131/-, Ornaments gold 1336.39 1285.08 Document 11 Annexure-1 Rajmal Lakhichand 169, Balaji Peth, Jalgaon Details of Total Sales for the period 01-04-08 to 31-03-09 Particular Sister concem Wgt Amt Bullion 859390.500 1229087840 Average Rate 1,372.68 Other Parties Wgt Amt Total Average Wgt Rate 2473435.98 Gold 4 Ornament 2977287.493 3974557623 1,334.96 3207646556 1,296.84 3368826.484 806309.915 1108936790 1,375.32 3783597.408 5083494413 Amt 4436734396 Gold Diamonds Stones 436820 Gold & 37171166 37607986 Stones Platinum Total 15,582 3872677.993 5204082283 3279761.48 44972 4353799484 2,886.15 15.582 7152439.474 44972 9557881....
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....0 563,232,427 3rd parties 4,685,150 1,417,979,076 287,585,700 3,207,646,557 373,584,461 59,279,978 Ornaments to Sister concern 901,412,851 828,668,584 819,940,200 3,975,475,586 1,642,657,208 1,513,747,607 Banks 3 parties 17,646,832 1,669,256,933 96,737,697 4,327,213,040 11,525,129 1,145,941,873 1,415,776,690 9,557,881,767 16,727,975 3,035,499,144 53,576,346 2,189,836,358 Labour Charges 3,340,024 Closing stock 34,163,339 645,978,383 41,981,462 76,624,617 64,215,659 23,383,683 31,119,833 85,977,676 42,649,399 Direct Incomes 95,340,858 (MTFGain) Sub Total 1,802,101,154 5,004,311,256 1,457,758,152 9,634,506,384 3,185,692,479 2,255,869,440 Opening Stock 52,263,352 575,306,146 168,551,291 84,522,861 25,389,330 Add: Purchases Bullion from Sister concern 162,659,000 402,937,239 219,803,839 Banks 914,455,727 1,622,200,585 921,322,881 4,198,775,360 469,757,500 590,174,769 366,712,183 1,280,312,596 362,748,024 3 parties 49,643,799 4,998 2,743,919 Ornaments Sister concern 602,718,403 1,555,923,248 294,502,15....