TaxTMI 
TaxTMI 
2023 (3) TMI 307
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....ause notice u/s 263, the Assessing Officer had raised specific queries, during the course of assessment proceedings and which were replied with numerous details and, thus, the Assessing Officer had, duly, applied his mind to all such details, copies of accounts and other voluminous details furnished to the Assessing Officer and had taken a conscious decision in respect of all the information and framed the assessment on the basis of the details furnished by the assessee. 3. That the Ld. PCIT, Panchkula had not considered the detailed reply of the assessee properly, furnished during the course of proceedings u/s 263 and had mislead herself, while giving a finding on various issues, particularly, ignoring the fact, that the deposit of cash during the demonetization period from 09.11.2016 to 31.12.2016 was to the tune of Rs. 97,45,000/-, against the deposit of cash during the same period i.e. from 09.11.2015 to 31.12.2015 to the tune of Rs. 97,50,000/-and, thus, has erred in holding that the assessment as framed by the Assessing Officer is erroneous and prejudicial to the interest of the revenue. 4. Notwithstanding, the above said grounds of appeal, the Ld. PCIT, Pan....
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....n to demonstrate that on facts more than adequate enquiries have been made by the AO in the present case before the passing of the order. It was submitted that infact the impugned order on the contrary is based on conjectures. All facts referred to in the Show Cause Notice by the PCIT, it was submitted, are emanating from the detailed queries made by the AO. These queries, it was submitted, have been replied to by the assessee. Referring to the order, it was submitted, that the ld.PCIT apart from reproducing the replies of the assessee to the AO has made no effort whatsoever to show how the reply made available to the AO and considered by the Assessing Officer is seen to be an error which is sought to be addressed by exercising the Revisionary powers u/s 263. 3.2 Reading from the order, it was submitted that from pages 1 to 4 of the synopsis filed contains the submissions highlighting the fact that the AO as per record was fully conscious of the fact that he was required to look into the cash deposits during the demonetization period. From para 4 onwards upto page 11 in the synopsis, it has been addressed that each and every shortcoming pointed out by the ld. PCIT had been enqui....
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....sessee which amongst other issues included specific queries on 'cash deposits' made not only in the different periods for the year under consideration but also required the assessee to provide these comparative details for the earlier years. Enquiry, it was submitted, was also made on cash sales by the assessee for these earlier years and the year under consideration. Thus, the facts in the present year were found similar to the earlier years. The enquiries and information provided on cash sales as per past practice looking at the assessee's peculiar customer base were all duly made. These were coupled with purchases made by the assessee not only for the year under consideration but also for the last 2 years. These were looked into in detail by making available comparative month-wise details. These were read out and relied upon. Inviting attention to pages 78 to 111 of the Paper Book, specific attention was invited to the covering letter at pages 78-79. Referring to the same, it was submitted that it would show that the assessee addressing the specific bank account had explained that during the demonetization period from 09.11.2016 to 30.12.2016 the cash deposits were explained....
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....ad provided the further details sought for by the AO. For ready reference, the said reply relied upon is extracted hereunder : 3.6 The ld. AR further submitted that the assessee is in trading of fertilizers and all purchases are largely from Government companies. It was further submitted that majority of its sales are made to licensed dealers in khad etc. who are appointed by Agriculture Department of Haryana and some retain sales are also made. The sales to the retailers have all along over the years has as a matter of practice been made in cash and also on credit basis. It was submitted that the assessee has been carrying on its business from two places, one is in Ambala functioning under the name of "Haryana Khad Store", and the other is at Yamuna Nagar working under the name of "Khurana Trading Co.". The assessee is proprietor of both. It was submitted that the return was filed on the basis of audited books of account and neither in the earlier year or subsequent year they have been faulted. The order passed by the AO, it was submitted, was after carrying out detailed enquiries on all facts. Considering the CBDT guidelines, it was submitted, not only facts for the year under....
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....ear 2015-16 and 2016-17 at page 127 and copy of the Ledger Account of Bonus payable in the books of Khurana Trading Co. from 01.04.2016 to 31.03.2018 at page 128. Attention was also invited to Paper Book page 129 copy of the reply dated 20.12.2019 which is filed before AO. Referring to the same, it was submitted that it addresses the nature of business of the assessee and also explains why cash sales have been made. It was submitted that as per record, the assessee had argued that the assessee's product 'fertilizer' used primarily by farmers as per past practice has always been purchased either from small scale retailers in rural areas or at times directly to the farmers in the rural areas. 3.10 Relying on these documents available it was submitted that the evidence demonstrating the nature of queries and the detailed replies received and cross checked by the AO was available to the ld. PCIT also. It was submitted that the order of the AO has been passed after seeing and examining these facts. Copy of this, it was submitted, has also been filed at page 130 and 131. The ld. PCIT it was submitted, had available on record the entire factual background of the queries raised and ....
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....the allegations that huge cash sale is unprecedented in the business history of the assessee, it was submitted is contrary to facts. It was submitted that as a matter of fact in the year under consideration, cash sales are less as compared to the earlier years. It was his submission that the modus-operandi of the assessee is that for the sales made to small scale outlets and small farmers at the time of the sale, if possible, the payments are collected and receipt may be issued etc. This has been a continuous practice of the assessee over the years as per record. Thus, it was argued that the record and past history is available on record. Month-wise details have been given. Accordingly, the allegations made by the Revenue based on conjectures, it was submitted, are de-hors the facts. Reply of the assessee dated 15.03.2022 at pages 145 to 149 was heavily relied upon. The said reply is extracted hereunder for ready reference : Date : 15.03.2022 To Pr. Commissioner of Income Tax Aayakar Bhawan, Sector-2, Panchkula. Sub ;- Notice u/s 263(1) of the income Tax Act 1961 for the A.Y. 2017-18 in the case of Sh. Gurcharan Singh, Prop. M/s Khurana Trading C....
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....sued to Sundry Debtors on receipt as cash from Sundry Debtors. Receipt Books have been produced before Ld. A.O. during the course of assessment. Further, it is informed that one receipt book is kept in office and another receipt books given to two to three persons who goes to different markets for collections on different routes on same date that i.e. pattern or sequence in the receipt No. are different because three to four receipt books used simultaneously. 8. In reply to para no. 4.5 of your notice, As already all the person know in one day Rs. 20000/- can be given in cash and at the time of collection Sundry Debtors given Rs. 20000/- in one day, which is valid as per provision of Section 40A(3) r.w. rule 6DD. 9. In reply to para no. 4.6 of your notice, no cash receipt entries/vouchers no. had been manipulated, cash is only received against material sold and from debtors against sales which record was already verified by Ld. A.O. during the course of assessment. Copy of debtors account already on the file submitted during the course of assessment. The A.O. verified all the documents like supporting purchase bills cash vouchers copy of accounts of respective deb....
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.... chart of cash deposit in financial year 2015-16 & 2016-17 is as under:- The Ld. A.O. thoroughly checked above said figures and from the above chart it is evident that Rs. 9750000/- has been deposited in bank, 09.11.2015 to 31.12.2015 which is not a demonetization period During the demonetization period 09.11.2016 to 31.12.2016 cash of Rs. 9745000/- has been deposited. Cash of Rs. 13141500/- has been deposited during the period 01.04.2016 to 08.11.2016 as compare to proceeding year Rs. 15823310/- during the period 01.04.2015 to 08.11.2015. Total cash deposit in Tank in financial year 2016-17 is Rs. 30748850/-as compare to total cash deposit in bank Rs. 32382310/- in the financial year 2015-16. I have also deposited the cash in the post demonetization period as per requirement of the business, the fact was duly explained during the course of assessment and documents are on the record. 14. During the demonetization period i.e. 09.11.2016 to 30.12.2016 cash amounting to Rs. 9745000/- (out of which Rs. 9400000/- is SBN) has been deposited out of cash available as on 08.11.2016 and out of sale proceeds of fertilizers etc. Certificate from Punjab National Bank, Main Bra....
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.... house hold expenses during the course of assessment and I have explained about house hold expenses to Ld. A.O. 19. Cash book for the period 01-04-2016 to 31-03-2017 has been produced for the verification during the course of assessment and Ld. A.O checked the cash book of every dates of full Financial Year. And copy of cash book for the period 01-04-2016 to 31-03-2017 placed on the file relevant to the A.Y. 2017-18. The ld. A.O has also checked the Balance of opening cash as on 01-04-2016 and closing cash of 08.11.2016. Keeping all the facts of the case & Explanation given to you & records produced for verification before Ld. A.O. above referred assessment order dated 24-12-2019 passed by ld. A.O Ward No. - 5, Yamuna Nagar is not erroneous and no loss to the interest of revenue, should not be cancelled Under Sec 263 of the income Tax Act, 1961. I hope that above information will satisfy you. Kindly do the needful and oblige. Thanking you, Yours faithfully, For Khurana Trading Co. Gurcharan Singh Mob: 9215500276 3.12 Attention was invited to the incorrect allegatiion that there was a mis-match in the postings. The re....
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.... absolute terms. 112-113 114 115-116 6 Copy of the reply submitted during the assessment proceedings along with the copy of the confirmation from the Punjab National Bank with respect to the cash deposited in the bank account during the AY 2017-18 in specified bank currency. 117-119 Copy of the reply submitted during the assessment proceedings wherein, the following details are submitted. 120 7 i) Month wise cash flow from 01.04.2015 to 08.11.2015 depicting the opening cash balance, cash sales during the year, cash deposited in the bank account and the closing balance of cash in hand. ii) Month wise cash flow from 01.04.2016 to 08.11.2016 depicting the opening cash balance, cash sales during the year, cash deposited in the bank account and the closing balance of cash in hand. 121 122 Copy of the reply filed during the course of assessment proceedings along with following details: 123 8 i)List of debtors from whom cash has been received during the demonetization period i.e. 08.11.2016 to 31.12.2016. 124-125 ii)Comparative details of cash deposited in the bank account of the assessee in....
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....eproduces from the record the facts already on record and conjectures without fact or evidence to hold that the order is to be set aside u/s 263. Assailing the order, it was vehemently argued that the ld. PCIT failed to point out any error in the order. Nothing has been brought on record to show what enquiry was still required to be done or what fact taken into consideration to hold that the Assessing Officer has passed the order on incorrect facts. No such fact or evidence has been referred to by the ld. PCIT. Admittedly also no enquiry to rebut any fact taken as a correct fact by the AO has been done by the PCIT. The order, it was his prayer may be quashed. The detailed reply made available to the ld. PCIT which has been extracted in the order from page 3 to 8 which reply is supported by the documents already referred to. These, it was submitted, have remained ignored for reason best left unaddressed. It was argued that the ld. PCIT arbitrarily seeks to compare the position upto 31.03.2016 and for un-stated reasons fails to consider that this is an ongoing business of the assessee where receipts in cash for sales made and recovery from some debtors is a continuing process and is ....
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....e and has required the assessee to re-file details as per the revised proforma complying with the CBDT instructions. The allegation of the ld. PCIT that these facts are incorrect is based on no evidence. As per record, the AO has examined and analyzed the past history, all replies available with the AO were available to the ld. PCIT. Before setting aside the order, it was submitted, it is incumbent on the ld. PCIT to show that what was the incorrect factor. Merely stating that these are bogus, sham, it was his submission is strongly objected to. Stock is available, sales have been made, none of this has been doubted. These are not cash credits. Thus, on the basis of enquiries carried out by the AO, replies of the assessee , there was no occasion for the ld. PCIT to conclude that it was a case of lack of enquiry. Referring to page 140 of the Paper Book, it was also referred to so as to highlight that this fact has been clarified in para 5.2 before the ld. PCIT. 3.14. Summing up the Show Cause Notices on record, it was argued that the allegations based on suspicions de-hors the facts was strongly objected to. These have been replied to and addressed in detail before the ld. PCIT a....
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....addressed. For ready reference, this reply at pages 145 to 149 has already been extracted. 3.16 Inviting attention to page 8 it was submitted that a perusal of paras 9 and 10 of the impugned order would show that the ld. PCIT has confused herself in considering the issue. Accordingly, the point-wise reply of the assessee in para 6 of the synopsis filed (specifically pages 5 to 12) was heavily relied upon requesting that these be taken on record as argued. The same is reproduced hereunder for completeness: The finding of the Ld. PCIT starts from para 5.1 and then PCIT has referred to the amount of cash deposits of Rs. 97,45,000/-, during the demonetization period and referred to certain point, which are being tabulated as under:- THE FINDING OF THE PCIT RE PLY OF THE ASESSEE a) At page 9 of the order u/s 263, the Ld. PCIT has mentioned about the difference of Rs. 1,09,57,578/- by comparing the debit as on 31.03.2016, with cash receipts from debtors and in response to that, she has referred to the reply of the assessee in para 5.2, that there is no difference, because cash has been received on account of sales and has referred to the sales of Rs. 16,28,23,973/- d....
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.... salesmen, besides, the collection of cash at the office premises, the receipts books are given to salesmen with different serial numbers and, thus, it is only a doubt, without any evidence. c). In para 7.1 of the order, the PCIT from the copies of accounts, which are confirmed copies of accounts has stated that why continuously cash receipt of less than Rs. 20000/-, are being received from the parties on day to day basis and then also stated that there is alleged manipulation made by the assessee, in respect of receipts from the debtors and then it has been mentioned that on certain receipts Voucher No/Receipt No. have not been mentioned and, thus, has submitted in para 7.4 that these are manufactured cash in hand. We strongly object to this remarks of the Ld. PCIT about the manipulation and manufactured cash in hand. It is submitted that even at times receipt No. has not been in the books, but the date of payment has been recorded in cash book, which tallies with receipt book and which has been confirmed by the parties, It gives no reason to PCIT to adversely comment upon the same. Further, there is no manipulation regarding alleged manufactured cash in hand, because ....
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....led for numerous details about the previous year cash deposits during demonetization period and for the whole financial year 2015-16 and 2016-17, which is evident from reply at page s 120, 122 and 123. Then he took notice of the collection of debtors at page 114, verified the quantitative details and asked for confirmed copies of accounts from the parties and most of them are licensed dealers by the Agriculture department, Haryana and, thus, the contention of the Ld. PCIT that no comparison of detail of monthwise cash receipts and deposits have been taken into consideration by the Assessing Officer is totally misleading. Further, the assessee is Sole Judge of carrying on its business and the Ld. PCIT cannot dictate as how to carry on the business. Reliance is being placed on the judgment in the case of S. A. Builders Ltd. as reported in 288 ITR 1. f). PCIT has referred in para 10.4 and 10.5 about the availability of cash in hand before the demonetization period and has stated that the assessee was maintaining a reasonable cash in hand but then in Ambala branch, there is cash in hand of Rs. 81,52,764/- on 02.10.2016 and has commented upon the fact that cash been manipulated. W....
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....the whole basis of clerical mistake have been taken by the Ld. PCIT for the purpose of action u/s 263, which proves that the Ld. PCIT was bent upon to take action u/s 263. Further, thus, when quantitative details are available, no adverse view can be taken of such clerical mistakes and how such inadvertent mistake lead to purchases not correctly recorded in the books or sales are inflated, is not borne out from the order of Ld.PCIT . h). The Ld. PCIT had stated that Godown rent has been disclosed in the profit and loss account and that investment of such Godown had not been considered by the Assessing Officer and assessee had submitted that it had shown income from Godown at Rs.90250/- and that investment in the Godown has not been disclosed. The assessee submitted that Godown was taken on rent @ Rs. 72,000/-per anum and the same Godown was let out to RCF Ltd. for Rs. 92,250/- and both have been disclosed in receipt and expenditure account side. It has been mentioned that the assessee had not divulged the detail of the owner of property and whether the assessee can sublet the property or not. The rent as received has duly been disclosed at page 66 of the Paper Book and on oth....
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....lied upon for this purpose, which are being relied upon. The finding in the above said starts from para 10. 8. Similarly, reliance is being placed on the judgment of ITAT, Chandigarh Bench in the case of 'Ganga Acrowools Limited', copy placed at pages 14 to 39 of the Judgment Set. The finding in the above said case is at page 32 para 6 and reliance has been placed on the various judgments at page 36 and on the Judgement of Hon'ble Punjab fit Haryana High and Others and the appeal of the assessee has been allowed. 9. Similar reliance is being placed on the judgment in the case of M/s Loil Continental Foods Ltd. and the extract of the finding is there at page 44 of the judgment Set and in para 17, it has been held as under:- "No doubt the assessment orders are very brief, and did not have elaborate discussion on these issues, but it is pertinent to bear in mind that assessees have no control over the AO and cannot persuade him to draft the assessment order in a particular manner. It is the discretion of the AO, how to pass an assessment order. Had an elaborate discussion available, then that would be an ideal situation for the higher appellate a....
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....n a similar issue the ITAT Chandigarh Third Member Bench in the case of Bansal Rice Mills Vs. ITO (supra) held that "since the sales proceeds have already been accounted for in the trading account no addition could be sustained even if the said deposits could be treated as bogus sales as complete stock tally was there". 10.5 In the present case also the assessee was maintaining complete stock tally, the sales were recorded in the regular books of accounts and the amount was deposited in the bank account out of the sale proceeds, therefore, the addition made by the AO and sustained by the Ld. CIT(A) was not justified." 14. Besides that number of other judgments of various High Courts and different Benches of the ITAT have been relied upon and, therefore, even on merits, it is submitted that no addition was called for on the basis of facts given by the Ld. PCIT in the order u/s 263." 3.18 In the said factual backdrop, it was submitted on behalf of the assessee that the order passed by the AO is after due application of mind and reliance was placed on the decisions considered by the Chandigarh Bench as noticed in the judgement set (filed on 31.05.2022) at Sl.No.2 ....
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....he Revisionary Powers has considered these facts and when these are considered in the proper perspective it changes the entire scenario and for this very purpose, the Revisionary powers are vested in the PCIT. It was his submission that no doubt information was available to the AO, however, nothing much turns on this as he has failed to examine it. The case of the Revenue is that the AO has failed to enquire into the explanation and neither has the assessee been able to demonstrate whether any enquiry was carried out despite the stated fact that the AO was conscious that this was de- monetization period. 4.1 Accordingly, in this backdrop, the ld. CIT-DR submitted that upto page 8, the facts and replies of the assessee have been considered in the order and thereafter from para 5 onwards has considered them in detail. Attention was invited to para 5.3 to show that no evidences were considered by the AO as he raised not even a single enquiry. Attention was invited to para 5.4 to submit that the assessee could not explain the mis-match of Rs.4 Cr odd. Inviting attention to page 11, it was submitted, that no field verification by the Income Tax Inspector by way of any Inspection Repo....
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....ed : 14.1 In this regard, the assessee has submitted that "total purchase during the year is Rs. 169138373 and sales are Rs. 172823973 for the financial year 2016-17. And as per stock register purchase value is 169138373/- and sale value is 172823973/- and there is no difference. During the course of assessment stock summary was prepared manually and there is clerical mistake which were explained during the course of assessment and stock register was produced before the Ld. A. O. and explained the value of purchase and sales and the Ld. A.O. satisfied with the explanation/stock register produced during the course of assessment. Thus amount of Rs. 5129659/- was not taxable as per section 69 r.w.s.115 BBE." 14.2 The said submissions of the assessee do not stand authenticated w.r.t. the relevant records. From the perusal of the assessment record, it is noticed that neither any query in this regard was raised by the AO, nor the assessee had furnished any explanation in this regard. Therefore, the vague explanation of the assessee in respect of this issue is found to be devoid of any strength. It is prima-facie evident from the Table above that the investme....
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....ee as bonus or commission as reported in Audit Report and as reported in the ITR. The assessee has submitted in this regard that "there is no mismatch amount paid to employees as business as reported in audit report and reported in ITR. Copy of audit report and ITR is on record and same has been verified by the La. AO that there is no mismatch during the course of assessment proceedings." It is, however, noted that not even a single query was raised by the AO in this regard. Obviously no verification was made by the AO to ascertain the correct facts on the given issue. 17. It is further noted that the assessee had shown drawings for his household expenses only at Rs. 1,80,000/- during the year under consideration. The AO accepted the said claim without batting an eyelid, despite the fact that the assessee had shown a turnover of about Rs. 15 crores. Even basic enquiries were not conducted by the AO to ascertain the size of the assessee's family, and expenses required to be incurred or essential items like electricity, telephone, vehicles, travel, medical needs, rent, daily provisions etc, commensurate with his status and standing in the society. 17.1 In this r....
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....e have heard the rival submissions and perused the material available on record. We find that though the parties have placed reliance on various decisions to canvass and support their point of view, however, before applying the ratios of the decisions cited by either party, it is necessary to first address the peculiar facts as it is only once the facts are culled out the ratios of decisions become applicable. In the facts of the present case, admittedly the assessee has been in this line of business for the last more than a decade or so. It is a matter of fact and not in dispute that the cash deposits on the specific dates noticed by the ld. PCIT in the year under consideration have been made by the assessee and these facts have not been disputed by the assessee. The assessee relying on record has canvassed that these facts were fully noticed by the AO and only after due enquiries, the assessment order is passed. The ld. PCIT considering the peculiar factual position in the year under consideration as a result of the demonetization scheme has considered the deposits questionable during this specific time. The AO admittedly has accepted these as duly explained. On facts, the ld. PC....
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....sly operates as a shield to protect the taxpayer or the Department from conjecturising on the issue. The initiative is laudable deserving appreciation. In the facts of the present case, we find that the availability of the information on the ITBA portal is a fact which the ld. PCIT cannot discard. The fact that in the assessee's business where the cash deposits in the banks being season driven, necessarily during this period over the years has shown that the assessee has available cash to deposit is evidenced and has been seen. Thus, the impugned order cannot be sustained. While so concluding, we have taken into consideration the various points highlighted by the ld. PCIT. Some of these we propose to address hereinafter :- 6.2.1 It is seen that the ld. PCIT has alleged that the cash receipt was less than Rs.20,000/- on each date. We find that this is not a fact for which the assessee is answerable as no sequences for receiving a higher cash is borne by the assessee. Similarly, the allegation that the vouchers were not in sequence stands addressed by the consistent explanation on record that the sales/recovery teams moved separately with different vouchers and hence having sa....
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....deposited smaller amounts on different dates is a valid explanation considering the then prevailing realities and cannot be outrightly discarded as an erroneous explanation accepted by the AO. We find that this consistent explanation remains ignored by the ld. PCIT. 6.3 Accordingly, on a consideration of the factual matrix of the present case, we find that the impugned order being arbitrary and whimsical on facts deserves to be quashed. It is not a case wherein the AO can be said to have passed the order without carrying out necessary enquiries. We have seen on record that the explanation offered by the assessee has been faulted with by the AO initially. The assessee has been required to re-file the same with proper comparative details addressing the reasons for the deposits made on different dates. The explanation is on record and has not been shown to be incorrect and infact the ground realities requiring the assessee to deposit the amounts on the specific dates has remained unrebutted on record. Historical factual position also remains unrebutted on record. Hence on a consideration of the entire facts and circumstances of the present case, we find that the impugned order dese....
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....ed, no labour register containing signature of labour and labour payment vouchers has been furnished, the payments have been made in cash without deducting tax at source which makes the payment suspicious and no independent enquiries have been made to verify wages payable being old one and therefore, the order so passed by the AO has been held as erroneous in so far as prejudicial to the interest of Revenue. 13. To our mind, where the matter is selected for precise reason for examination of labour and wages payable, certain basic questions arises for consideration which a person of reasonable intellect and understanding should raise and examine. Firstly, who are these persons - whether regular employees or hired through a third party, name and address and other basic identification particulars of these persons who are hired and terms of such hiring in terms of salary/wages/social security, etc., work/project for which they are hired and their attendance records, etc to establish actual rendering of services and period/hours of service, payment/muster rolls etc showing salary/wages payable, actual payment and whether liable for TDS and actual TDS done and deposited in their....
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.... conclusion that the AO has failed to carry out adequate and proper enquiries which he should have conducted in respect of labour and wages payable. 9. Accordingly, on account of the detailed reasons on facts and position of law, we quash the impugned order. 10. In the result, appeal of the assessee is allowed. Order pronounced in the Open Court on 02 Jan.,2023. ============= Document 1 To The Income Tax Officer, ne Tax Omoe. 5. Yamuna Nagar. Baklass A Preseeding for the mean Year 2017-18. With reference to assessment proceeding for the assessment year 2017-18. 1 am subasitting the following required documents/ information: 1. During the demonetization period i.e. 09.11.2016 to 30.12.2016 (SEN) cash mounting to Rs. 4000000 has been deposited in Punjab National Bank, Main Branch , Yamuna Nagar having acement No. 0471008700007835. The detail of which is as under- Atnes 10.11.2016 11.11.2016 1.11.2016 13.11.2016 21.11.2016 Amana B 900000 9000 900000 900000 400000/- Total (Rs.) 4000000/ (SBN) cash aniounting to Rs. 5400000/- has been deposited in Punjab National Bank, Main Branch,....
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....-18. 1 am submitting the following required documents/ information: 1. The said firm is engaged in whole sale trading of fertilizers etc. situated at Shop No. 11, Anaj Mandi, Yamuna Nagar. 2. Copies of accounts all the major expenses debited to profit & loss accounts of M/s Haryana Khad Store, Ambala are enclosed. All the expenses are incidental to business. 3. Bank Statement and copy of ledger account of all the bank accounts maintained during the year is enclosed, 4. Detail of comparative figures of sales, gross profit and G.P. & N.P. rate for the last three years are en under- Xear 2016-17 2015-16 2014-15 Sales Tarnover 178972495/- 147646704/- 109806428/- Gross Profit 4404086/- 3353448/ 2387811/ Net Profit 1455506/- 1206318/- 879906/- G.P.Bate 2.46% 2.28% 2.18% N.P. Bate 0.81% 0.81% 0.80% There is no fall in O.P. & N.P. rate during the year.. 5. Month wise detail of purchases and sales along with quantity and value is enclosed. 6. Stock has been valued at cost or market price whichever is lower. Quantative Detail of opening & closing stock is enclosed. 7. There is no....