Turnover cannot be estimated upward on mere suspicion when accepted books show no defect or under-invoicing.

A dealer's declared turnover cannot be enhanced on mere suspicion when the books of account are regularly maintained, accepted as reliable, and no defect, under-invoicing, price suppression, or other adverse material is established. The invoice value shown on transfer to a depot was treated as only an approximate value, not the purchase price, and no investigation produced evidence justifying a higher estimate. On those facts, the attempted upward estimation was unjustified and the declared turnover had to be accepted.

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Issues: Whether the turnover declared by the dealer could be enhanced without rejection of the books of account or proof of any defect, under-invoicing, or adverse material justifying an estimate higher than the returned turnover.

Analysis: The books of account were found to have been regularly maintained and were neither rejected nor held unreliable. No defect, under-invoicing, loss, or price suppression was established. The invoice value shown on transfer to the depot was only an approximate value and not the purchase price. In the absence of any investigation yielding adverse material, the turnover could not be enhanced merely on suspicion or conjecture.

Conclusion: The enhancement of turnover was unjustified and the declared turnover was required to be accepted.

Ratio Decidendi: Turnover cannot be estimated upward on mere suspicion where the dealer's books of account are accepted and no adverse material, defect, or under-invoicing is established.

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