Estimated turnover cannot rest on one day sales alone; addition and penalty fail without reliable corroborative material.

An assessment based solely on one day's sales was found unsustainable where the Revenue did not independently establish any omission or suppression. The Court held that extrapolating one day sales to the entire year was not a scientific or legally reliable method, particularly without accounting for normal, festive, seasonal, or other trading variations. The Tribunal's view that the estimated addition was unjustified was upheld, and the consequential penalty could not survive because the underlying addition failed. The appellate authorities' modified assessment was therefore left undisturbed.

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Issues: Whether the assessment based solely on one day sales could sustain the addition for the entire year and the consequential penalty.

Analysis: The assessment was founded only on one day sales and materials collected during inspection. The authorities below found that no omission or suppression was independently established by the Revenue. The Court held that taking one day sales as the basis for estimating the whole year's turnover was not a scientific or legally sustainable method, particularly without considering normal, auspicious, inauspicious, festive or seasonal variations. The Tribunal's view that the estimated addition was unjustified was found to be correct.

Conclusion: The addition based on one day sales was unsustainable and the penalty could not survive.

Final Conclusion: The Revenue's challenge failed and the assessment as modified by the appellate authorities was left undisturbed.

Ratio Decidendi: An estimation of suppressed turnover cannot rest merely on one day sales unless supported by cogent corroborative material showing a reliable basis for extrapolation to the entire assessment period.

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