Best-judgment assessment requires relevant material and a fair estimate; unsupported turnover additions and CST restoration could not stand.

Best-judgment assessment must rest on relevant material and a fair approximation, not a rule-of-thumb estimate. The Tribunal could not restore a Central Sales Tax addition without addressing the appellate finding that there was no material to show inter-State sales and without considering the effect of the remand in the State proceedings. An estimated turnover of Rs. 40,000 also failed because the assessment order disclosed no supporting material and did not show an honest, rational basis for the figure. The Tribunal's order was set aside and the matter remitted for fresh decision in accordance with law.

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Issues: (i) Whether the Tribunal could restore the best-judgment addition under the Central Sales Tax Act without considering the appellate finding that there was no material to show inter-State sales and without awaiting the result of the remand under the State Act. (ii) Whether the turnover estimated at Rs. 40,000 could be sustained when the assessment order disclosed no material and the estimate was made on a rule-of-thumb basis.

Issue (i): Whether the Tribunal could restore the best-judgment addition under the Central Sales Tax Act without considering the appellate finding that there was no material to show inter-State sales and without awaiting the result of the remand under the State Act.

Analysis: The remand ordered in the State assessment was relevant because the assessee's case was that no business, manufacturing, or sales activity had taken place during the year. The appellate authority had also deleted the Central Sales Tax addition on the distinct finding that there was no material to support inter-State sales. The Tribunal reversed the appellate order without dealing with that finding and without considering that the remand proceedings could affect the foundation of the addition.

Conclusion: The Tribunal's restoration of the addition was unsustainable.

Issue (ii): Whether the turnover estimated at Rs. 40,000 could be sustained when the assessment order disclosed no material and the estimate was made on a rule-of-thumb basis.

Analysis: Rejection of books of account does not permit a punitive or arbitrary estimate. Even in best-judgment assessment, the estimate must have some nexus with relevant material and must represent an honest and fair approximation of turnover. The assessing authority's order did not refer to any supporting material, and the Tribunal upheld the estimate without proper application of mind to that requirement.

Conclusion: The estimate of turnover could not be sustained.

Final Conclusion: The revision was allowed, the Tribunal's order was set aside, and the matter was sent back for fresh decision in accordance with law.

Ratio Decidendi: Best-judgment assessment must be based on relevant material and a fair estimate, and a revisional or appellate authority cannot sustain an addition without addressing adverse findings and the evidentiary basis for the estimate.

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