Estimated manufacturing shortage must rest on proper evidence; revision failed because no question of law was shown.

Tax cannot be disallowed on mere surmise or guesswork; the assessing authority should base any estimate of manufacturing shortage on industry data, past figures, or comparable material from similar manufacturers. The High Court found no infirmity in the Tribunal's view that the claimed raw material shortage had not been properly rejected and held that the petitioner failed to demonstrate any question of law. As revision under the revisional provision lay only on a question of law, interference was unwarranted and the Tribunal's order stood upheld.

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Issues: Whether the Tribunal's finding on disallowance of shortage of raw material in the manufacturing process called for interference in revision, and whether any question of law arose for consideration under the revisional provision.

Analysis: The Tribunal had recorded that tax could not be levied merely on surmises or guesswork and that the assessing authority, before disallowing the claimed shortage, ought to have placed on industry data, past figures, or comparative material from similar manufacturers. The High Court found no infirmity in this approach and held that no reason had been shown why the assessing authority could not have adopted a proper method for estimating loss during manufacture. Since revision lay only on a question of law, and the petitioner failed to demonstrate any such question, the revisional interference was unwarranted.

Conclusion: The revision was not maintainable on the facts presented, and the Tribunal's order was upheld.

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