Best-judgment turnover estimation upheld where unreliable accounts and missing records justified a reasonable business increase.

Unreliable accounts justified best-judgment assessment of turnover where the dealer failed to maintain or produce essential records such as purchase vouchers, cash book, ledger and stock register. Sales vouchers alone were treated as an insufficient basis for ascertaining true turnover. The appellate authority erred by ignoring the dealer's inconsistent stand on purchase vouchers and by not applying the settled approach that, in the absence of better material, a normal business increase may be used as a reasonable estimate. The revisional authority was therefore justified in correcting the appellate order, and the 15 per cent enhancement of turnover was upheld.

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Issues: Whether the Deputy Commissioner was justified in exercising suo motu revisional jurisdiction to revise the appellate order and sustain enhancement of the dealer's turnover by 15 per cent for the assessment year 1969-70.

Analysis: The dealer had not maintained or produced the essential account books, including purchase vouchers, cash-book, ledger and stock register, and reliance on sales vouchers alone did not provide a trustworthy basis for determining the true turnover. Once the accounts were rejected, the assessing authority was entitled to estimate turnover by best judgment. The appellate authority had ignored the contradictory position taken by the dealer regarding production of purchase vouchers and had failed to apply the settled approach that, where no better material is available, a normal increase in business may be adopted as a reasonable basis of estimation. In these circumstances, the revisional authority was justified in correcting the appellate order.

Conclusion: The revisional order was valid and the enhancement of turnover by 15 per cent was upheld.

Ratio Decidendi: Where the dealer's accounts are unreliable and no adequate material exists to determine turnover, the authority may estimate turnover on a reasonable best judgment basis, including by applying a normal business increase.

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