Best judgment turnover assessment requires a rational factual basis; an unsupported formula for groundnut oil sales was arbitrary.

A best judgment assessment of groundnut oil turnover was held unsustainable where the assessing authority adopted a turnover formula without supporting material. The authority assumed that groundnut oil sales were 3.5 times oil-cake sales solely because of price differences, but there was no evidence of the actual production ratio from crushing groundnuts and no finding that oil and oil-cakes were produced in equal quantity. In the absence of a factual foundation, the method of computation lacked a rational basis and was arbitrary, so the assessment was quashed.

---

---

Issues: Whether the best judgment assessment of groundnut oil turnover was sustainable when the assessing authority adopted a basis not supported by material on record.

Analysis: The turnover was computed by assuming that groundnut oil sales were 3.5 times the sales of oil-cakes merely because of the difference in average sale prices. No material showed the actual proportion in which oil and oil-cakes are produced on crushing groundnuts, and no finding established that they are produced in equal quantity. In the absence of such material, the adopted formula lacked a rational basis and was arbitrary.

Conclusion: The assessment of groundnut oil turnover was not sustainable and was liable to be quashed.

---