Final fact-finding authority must give independent reasons before upholding a best judgment assessment.

An appellate tribunal acting as the final fact-finding authority must independently examine the material, assess whether rejection of the assessee's accounts was justified, and record its own reasons before sustaining a best judgment assessment. Mere affirmation of the lower authority's conclusion, without a fresh appraisal of the factual basis or the method of estimation, is inadequate. Where the tribunal adopts a different view for other years but gives no independent reasons for the year in question, its order is unsatisfactory and cannot stand. The matter was remitted to the tribunal for disposal according to law.

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Issues: Whether the appellate tribunal, as the final fact-finding authority, was required to independently examine the basis of the best judgment assessment and give its own reasons before sustaining the assessment.

Analysis: The assessment was made by rejecting the assessee's accounts and applying a best judgment formula. The appellate authority gave no independent reasons for adopting the formula for one assessment year, even though it had found the same approach inapplicable for the other years. The tribunal, in turn, merely affirmed the conclusion without undertaking a fresh appraisal of the facts or addressing the correctness of the rejection of accounts and the method of estimation. As the final fact-finding body, it was required to examine the matter afresh and record its own conclusion on whether rejection of accounts was justified and, if so, the proper method of estimation.

Conclusion: The tribunal's order was unsatisfactory and could not be sustained; the petition succeeded and the matter was remitted to the tribunal for disposal according to law.

Ratio Decidendi: A final fact-finding appellate authority must independently evaluate the material and record reasons before affirming a best judgment assessment.

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