Assessment year specificity and cogent reasons govern whether returned figures can be rejected or accepted in appellate review.

Assessment is year-specific, so a view taken for one assessment year does not bind the Tribunal for another year merely because the materials are identical, though any departure from an earlier view must be justified by reasons on the record. Where the Sales Tax Officer and the appellate authority have rejected returned figures and treated the case as fit for best judgment assessment, the Tribunal cannot direct acceptance of those figures without cogent reasons based on the materials. The article states that the Tribunal was not justified in reversing the concurrent rejection of the returned figures and that the matter was remitted for rehearing and disposal according to law.

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Issues: (i) whether a view taken for one assessment year binds the Tribunal for another assessment year on identical materials; (ii) whether the Tribunal could direct acceptance of returned figures without cogent reasons after the lower authorities had rejected them.

Issue (i): whether a view taken for one assessment year binds the Tribunal for another assessment year on identical materials.

Analysis: Assessment is year-specific, and a different view for a different year is not barred merely because the materials are similar. However, the Tribunal must still justify any departure from an earlier view by reference to the record and the reasons for change.

Conclusion: A different view for another assessment year is permissible, but not as an automatic consequence of identical materials.

Issue (ii): whether the Tribunal could direct acceptance of returned figures without cogent reasons after the lower authorities had rejected them.

Analysis: Where the Sales Tax Officer and the appellate authority have declined to accept the returned figures and have found the case fit for best judgment assessment, the Tribunal cannot reverse that conclusion without giving acceptable and cogent reasons based on the materials. The Tribunal's direction to accept the returned figures was unsupported by adequate reasoning.

Conclusion: The Tribunal was not justified in directing acceptance of the returned figures.

Final Conclusion: The reference was answered against the department on the actual question arising, and the matter was sent back for rehearing of the second appeal and disposal according to law.

Ratio Decidendi: A Tribunal may take a different view for a different assessment year, but if it reverses concurrent findings rejecting returned figures, it must record cogent reasons grounded in the materials on record.

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