Best judgment tax assessment requires supporting material; conjecture and unsupported extrapolation cannot sustain writ interference.

A best judgment sales tax assessment must rest on relevant material and a fair estimate; it cannot be sustained on bare suspicion, conjecture, or extrapolation from isolated check-post declarations. The assessing authority relied only on declarations from two dates and assumed, without evidence, that similar quantities were transported weekly throughout the year. That approach was held arbitrary and unsupported by material. The existence of an alternative remedy did not bar interference where the assessment was fundamentally vitiated by absence of evidence and unfair process. The assessment was quashed in writ jurisdiction.

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Issues: Whether a best judgment sales tax assessment made without supporting material, and based only on conjectures and surmises from limited check-post declarations, could be sustained in writ jurisdiction under Article 226.

Analysis: A best judgment assessment permits an element of guesswork, but the estimate must rest on some material and cannot be founded on bare suspicion or pure conjecture. The assessing authority relied only on declarations relating to two isolated dates and assumed, without any evidentiary basis, that similar quantities were transported every week throughout the year. Such an extrapolation was held to be arbitrary and unsupported by material. The existence of an alternative remedy did not prevent interference where the assessment was fundamentally vitiated by absence of material and violation of fair process.

Conclusion: The assessment could not be sustained and was quashed; the writ petition was allowed in favour of the petitioner.

Ratio Decidendi: A best judgment assessment must be based on relevant material and a fair estimate, and cannot rest on pure conjecture or suspicion.

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