Best judgment turnover estimation upheld where defective accounts and suppression of sales made the books unreliable.

Rejection of the assessee's books of account and estimation of turnover on a best judgment basis were upheld because the authorities and the Tribunal concurrently found the accounts unreliable due to defects noticed in surprise inspections and admitted irregularities, including suppression of sales. The Tribunal's reduction and modification of the additions was treated as reasonable on the facts, and the High Court found no legal infirmity in the estimation process. As the dispute rested on factual findings and disclosed no question of law, interference in revision was not warranted, and the revision was rejected.

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Issues: Whether the rejection of the assessee's books of accounts and the estimation of turnover on best judgment basis gave rise to any question of law warranting interference in revision.

Analysis: The books of accounts were rejected on the basis of defects noticed in surprise inspections and the admitted irregularities, including suppression of sales. The authorities below and the Tribunal concurrently found that the accounts were unreliable and that best judgment assessment was the only feasible method. The Tribunal reduced and modified the additions in a manner found to be reasonable on the facts. The Court held that the additions were founded on findings of fact and that no legal infirmity was shown in the estimation of turnover. In the absence of any question of law, interference in revision was not called for.

Conclusion: The revision was not maintainable on any question of law and was rejected.

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