Best judgment turnover estimation: revision fails where the Tribunal adopts a rational method and the finding is not perverse.

In a best judgment assessment, the quantum of turnover estimation is primarily for the final fact-finding authority, and revision lies only where the estimate is vitiated by ignoring material evidence, considering irrelevant factors, or reaching a perverse or irrational conclusion. The Tribunal examined stock variation, business locality, competition, prior assessments and surrounding circumstances, and gave reasons for rejecting the running-stock method as the sole basis. It adopted a 100 per cent addition to returned turnover as a reasonable estimate, and the revisional court found no illegality or perversity and declined interference.

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Issues: Whether the Tribunal's estimate of taxable turnover by making 100 per cent addition to the returned turnover, instead of adopting the multiple of running stock, was so unreasonable, unfair, irrational or perverse as to warrant interference in revision.

Analysis: In a best judgment assessment, the quantum of estimation is a matter for the final fact-finding authority and may be based on any rational and tenable method having nexus with the proved facts. Interference in revision is justified only if the finding is vitiated by ignoring relevant materials, considering irrelevant factors, posing the wrong question, or reaching a conclusion that is unfair, perverse or irrational. The Tribunal evaluated the stock variation, the locality and competition of the business, the previous assessments and other surrounding circumstances, and recorded reasons for discarding the running-stock method as the sole basis. It then adopted an ad hoc addition of 100 per cent to the returned turnover as a more reasonable estimate.

Conclusion: The Tribunal's estimate was not shown to be illegal, irrational or perverse. The revisional court declined to interfere, and the Revenue's revisions failed.

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