Best judgment assessment upheld where inspection-linked turnover suppression supported a reasonable estimate, defeating revisional interference.

Best judgment assessment based on a surprise inspection and detected suppression of turnover was held to be within the assessing authority's domain, and revisional interference was unwarranted absent arbitrariness, caprice, vindictiveness, or lack of bona fides. The inspection revealed unaccounted sales and stock discrepancies over 24 days, and the yearly estimate was drawn from that material with a rational nexus to the suppression found. Limited relief had already been granted at the appellate stage by reducing the multiplier after noticing duplication in the addition. The estimation was therefore treated as reasonable and supported by material, and the tax revision failed.

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Issues: Whether the revisional court could interfere with a best judgment assessment made on the basis of a surprise inspection and detected suppression of turnover; and whether the estimation adopted in assessment was arbitrary or reasonable basis.

Analysis: Best judgment assessment is primarily for the assessing authority, and the revisional court cannot substitute its own estimate unless the assessment is shown to be unfair, unreasonable, capricious, vindictive, or lacking bona fides. The surprise inspection disclosed unaccounted sales and stock discrepancies over a period of 24 days, and the assessing authority drew an estimate for the year from those material facts. The appellate authority also examined the figures, found an element of duplication in the addition, and granted limited relief by reducing the multiplier. On the record, the estimate had a rational basis and a reasonable nexus with the discovered suppression.

Conclusion: Interference with the best judgment assessment was not warranted, and the estimation could not be characterised as arbitrary or unsupported by material; the revision failed.

Final Conclusion: The assessment and the reduced estimate were left undisturbed, and the tax revision stood dismissed.

Ratio Decidendi: A best judgment assessment will not be interfered with in revision where it is founded on material discovered in inspection and bears a reasonable nexus to the detected suppression, unless it is shown to be arbitrary, capricious, or lacking bona fides.

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