Revisional interference in assessment fails where accounts are defective, limitation is inapplicable, and turnover estimate shows no perversity.

Revisional interference with an assessment is unwarranted where the original assessment is not time-barred, the books of account are incomplete or unavailable, and the turnover estimate is supported by material defects. The note states that a limitation objection had no relevance on the facts because the matter concerned an original assessment, not an escaped assessment. It also records that rejection of the accounts was justified by grave defects and that the estimate could not be disturbed absent demonstrable perversity or other error. No ground for revision was found, and the tax revision cases were dismissed.

---

---

Issues: (i) whether the original assessment was barred by limitation; (ii) whether rejection of the books of account and the turnover estimate made by the authorities called for interference.

Issue (i): whether the original assessment was barred by limitation.

Analysis: The objection was founded on limitation, but the assessment in question was an original assessment and not an escaped assessment. The Tribunal had already considered the contention and found that the limitation plea had no relevance on the facts of the case.

Conclusion: The assessment was not barred by limitation.

Issue (ii): whether rejection of the books of account and the turnover estimate made by the authorities called for interference.

Analysis: The books were found to be incomplete and unavailable both at the factory and at the head office. The defects were treated as grave, and the estimate of turnover was made after considering relevant factors. In revision, interference was unwarranted in the absence of demonstrable perversity or other error.

Conclusion: Rejection of the books of account and the turnover estimate were upheld.

Final Conclusion: No ground was made out for revisional interference, and the tax revision cases were dismissed.

Ratio Decidendi: Revisional interference with an assessment is unwarranted where the original assessment is not time-barred, the rejection of accounts is supported by material defects, and the turnover estimate discloses no demonstrable perversity.

---