Rejection of unreliable accounts and estimated turnover addition upheld where no error of law was shown.

After the assessee's accounts and returns were rejected as unreliable, the dispute narrowed to the proper basis for estimating suppressed turnover. The Tribunal, as final fact-finding authority, found no material to show outside-State purchases and therefore confined the addition to one and a half times the actual suppression detected, without allowing the 80 per cent exemption claimed. The High Court treated the estimate as minimal but found no error of law in the Tribunal's approach, so the revision was not entertained on that ground.

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Issues: Whether, after rejection of the assessee's accounts and returns as unreliable, the Appellate Tribunal was justified in sustaining the addition at 11/2 times the suppressed turnover and in limiting the addition by exempting 80 per cent thereof.

Analysis: The accounts and returns were found unreliable and the rejection of accounts was upheld. In that situation, the matter turned only on the extent of estimate to be adopted against the returned turnover. The Tribunal, acting as the final fact-finding authority, found no material showing any purchase from outside the State and confined the addition to 11/2 times the actual suppression detected. The Court found that this estimate was minimal but did not disclose any error of law.

Conclusion: The Tribunal's estimate was upheld and the revision failed.

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