TaxTMI 
TaxTMI 
2025 (9) TMI 1571
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....owing grounds of appeal :- "1. On the facts and in the circumstances of the case and in law, the CIT (A) has erred in deleting the addition on account of disallowing salary paid to the Director of Rs. 15,00,000/- made by the Assessing Officer. 2. Om the facts and in the circumstances of the case and in law, the CIT (A) has erred in deleting the addition of Rs. 7,97,08,855/- made by the Assessing Officer on account of low GP rate." 2. With regard to ground no.1, relevant facts are, the assessee is engaged in the business of manufacturing of mobile phone parts. The AO observed that the assessee has paid remuneration of Rs. 15 lakhs to the director Ms. Seran Lee and the AO asked the assessee to justify the payment of this ....
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....the time of hearing, ld. DR of the Revenue submitted that assessee has failed to produce the documents related to the professional/academic qualification of the director and to justify the amount of remuneration paid to her before the AO and objected to the relief given by the ld. CIT(A). 6. On the other hand, ld. AR of the assessee relied on the findings of the ld. CIT (A). 7. Considered the rival submissions and material placed on record. We observe that Ms. Seran Lee is a Director and a Korean National. It is brought to our notice that she is well qualified and continued to do the services of the Director in the company. She has already declared the complete remuneration received from the company in her return of income, therefore,....
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....AO. The AR has furnished the reasons for fall in GP & NP rate. The AR has relied upon various case laws challenging the decision of the AO. I have perused the complete facts of the case. It is observed that the AO has made the addition in a summary manner without pointing out any defect/ in the maintenance of the books of account by the appellant. It is surprising that the books have been rejected without calling for the same. No reason has been specified to reject the explanation given by the appellant to justify the fall in GP & NP rates. I am of the opinion that the AO has wrongly rejected the books of account without furnishing any just and proper reason and also without providing any opportunity to the appellant. Merely because there w....
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....ched on a daily basis. There are instances where there is difficulty in achieving the quality desired by the customer, this leads to increase in costs due to rejection. Also, costing is controlled by the customer. The customer controls the sales price. Hence, the assessee who is a contract manufacturer has to abide by the customers decision. The assessee is subject to various laws and audits and books of account of the assessee are accepted by all authorities, Detailed information on purchase of raw material and sale of finished goods for the years 2014- 2015 and 2015-2016 is enclosed at Annexure "E". 14. Since the assessee has explained the reasons for fall of GP and NP, we observe that the AO has rejected the books of....