Best judgment assessment upheld where detected suppression supported a rational estimate of escaped turnover across earlier fortnights.

Best judgment assessment was upheld where inspection slips disclosed actual suppression for a limited period and provided a factual basis to reject the accounts. The estimating authority was not required to prove the exact suppressed turnover, so long as the estimate had a rational nexus with the detected facts and was not arbitrary. Extrapolation of the suppression to earlier fortnights was found not to be illegal or unreasonable, and the assessee's failure to produce further material did not undermine the estimate.

---

---

Issues: Whether the estimating authority was justified in adopting a best judgment assessment by extrapolating the suppressed turnover detected during the inspection to the earlier fortnights of the assessment year.

Analysis: The slips recovered during inspection disclosed actual suppression for a limited period and furnished a factual basis for rejecting the accounts and proceeding on best judgment. In estimating escaped turnover, the assessing authority was not required to prove the exact amount suppressed, provided the estimate had a rational nexus with the facts discovered and was not arbitrary. The absence of further material from the assessee did not disable the authority from making a reasonable estimate. The addition based on sixteen fortnights was therefore not shown to be illegal or unreasonable, and the appellate interference lacked material foundation.

Conclusion: The estimation of suppressed turnover was upheld and the assessee's challenge failed.

---