Estimated assessment of first sales upheld where dealer's accounts did not distinguish first and later sales.

Where a dealer kept no separate accounts for first sales and later sales in iron and steel goods, the assessing authority could determine first sales on an estimated basis. The Tribunal upheld that approach, and revision was declined because estimated assessment is a matter of degree and there was no clear material showing error in the estimate. Earlier similar orders in the assessee's own case had also been left undisturbed, supporting non-interference.

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Issues: Whether the revisional court should interfere with an assessment based on estimate of first sales where the dealer's accounts did not distinguish first sales from second or subsequent sales.

Analysis: The dealer maintained no separate reckoning of first sales and later sales in iron and steel goods. In the absence of clear accounts or other material, the assessing authority adopted an estimated basis for determining first sales, and the Tribunal affirmed that approach. Interference in revision was declined because assessment by estimate involves a question of degree, and similar orders in the assessee's own case for earlier years had already been left undisturbed.

Conclusion: The estimated assessment was not interfered with in revision.

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