Best judgment assessment requires supporting material; an estimate based only on the prior year was held unsustainable.

A best judgment assessment must be based bona fide on some material capable of reasonably supporting the estimate, not merely on the previous year's assessment. The assessment here gave no disclosed basis for the increase in turnover, no explanation for excluding inter-State sales, and no rationale for apportioning the balance turnover at different tax rates. The revisional order also treated the earlier year as a sufficient yardstick without showing how it supported the estimate. The estimate was therefore not reasoned but imaginary, and the assessment was quashed as unsustainable.

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Issues: Whether the best judgment assessment made under section 18(6) of the M.P. General Sales Tax Act was sustainable when it was based only on the previous year's assessment and not on any disclosed material or enquiry.

Analysis: A best judgment assessment must still be made bona fide and on some material capable of reasonably supporting the estimate. The assessment order gave no basis for the alleged increase in turnover, no explanation for the exclusion of inter-State sales, and no rationale for apportioning the balance turnover at different tax rates. The revisional order also treated the earlier year's assessment as a sufficient yardstick without showing how it could support the impugned estimate. On these facts, the assessment was not a reasoned estimate but an imaginary one.

Conclusion: The assessment was unsustainable and was rightly quashed.

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