Best judgment reassessment under sales tax law is permitted when statutory conditions for estimated assessment are satisfied.

Reassessment of escaped turnover under section 15(1) of the Bombay Sales Tax Act, 1953 can include best judgment assessment because the provision incorporates the assessment procedure and powers applicable to regular assessment under section 14. When a dealer fails to produce evidence, or submits false, unreliable, or suppressed accounts, the reassessing authority may move beyond a mechanical recomputation of escaped turnover and make a fair, honest estimate based on relevant material. The reassessment power is therefore coextensive with the read-in powers under section 14 where the statutory conditions for best judgment assessment are satisfied.

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Issues: Whether, on reassessment of escaped turnover under section 15(1) of the Bombay Sales Tax Act, 1953, the authority had power to make a best judgment assessment.

Analysis: The notice under section 15(1) triggers the reassessment machinery and, by the closing words of that provision, the provisions governing regular assessment under section 14 apply as if the notice were one under section 14(3). The scheme of sections 14 and 15 shows that once the dealer is called upon to produce evidence and fails to comply, or produces false, unreliable, or suppressed accounts, the authority may proceed under the powers corresponding to sections 14(4) to 14(7). Reassessment is therefore not confined to a mechanical computation of the escaped turnover already proved by direct material; it may proceed on the basis of a best judgment estimate, provided the estimate is a fair and honest one based on relevant material.

Conclusion: The reassessing authority was competent to make a best judgment assessment under section 15(1) when the conditions for such assessment existed under the read-in provisions of section 14.

Ratio Decidendi: Where the reassessment provision expressly incorporates the procedure and powers applicable to regular assessment, the authority may make a best judgment assessment in reassessment proceedings if the dealer defaults or the statutory conditions for such assessment are satisfied.

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