Reasonable income estimate justifies deletion of interest demand where the return was accepted on the facts.

Where an assessee's returned income was accepted as a reasonable estimate having regard to the nature and turnover of the business, deletion of interest levied under sections 139(8) and 215 was sustained. The appellate authority and the Tribunal treated the estimate as adequate on the facts, and the record disclosed no error in that reasoning or in the exercise of jurisdiction. The interest demand therefore remained deleted, and the issue was answered in favour of the assessee and against the Revenue.

---

---

Issues: Whether the deletion of interest charged under sections 139(8) and 215 was justified on the facts of the case.

Analysis: The assessee had returned an income that was treated by the appellate authority as a reasonable estimate having regard to the nature and turnover of the business. On that basis, the appellate authority deleted the interest levied under sections 139(8) and 215, and the Tribunal sustained that view. The record disclosed no error in the exercise of jurisdiction by the Tribunal or in the reasoning adopted for setting aside the interest demand.

Conclusion: The deletion of interest under sections 139(8) and 215 was upheld, and the issue was answered against the Revenue and in favour of the assessee.

Final Conclusion: The reference was answered in favour of the assessee, with the levy of interest remaining deleted.

Ratio Decidendi: Where the assessee's return of income is accepted as a reasonable estimate on the facts, the deletion of interest levied under sections 139(8) and 215 can be sustained on appeal.

---