I asked the same question a while back on StackOverflow and,
supposedly, upgrades do not count as an uninstall and a new install.

http://stackoverflow.com/questions/2210653/how-is-the-active-installs-count-percentage-in-the-android-developer-console



On Aug 26, 10:47 am, Fabrizio Giudici <[email protected]>
wrote:
> I've spotted this thread only now. It's happening to me too - in a
> week it dropped from a _steady_ 45% (held since several weeks) to 36%,
> with a single new active install out of regularly increasing new
> downloads. I even posted that on my blog - a commenter pointed out
> that when people upgrade an app the download counter might increase,
> while the active install doesn't (actually, I've released two updates
> in this month). Can you confirm?

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