Best judgment turnover estimates must rest on cogent material, not conjecture; arbitrary fixation was remanded for fresh determination.

Best judgment assessment requires turnover estimates to rest on cogent material and rational considerations, not conjecture or extrapolation from a brief sales survey. For perishable consumable goods, sales patterns must be assessed against market realities, and past assessment history remains a relevant factor in fixing a reasonable figure. Applying these principles, the Tribunal's turnover estimate was found arbitrary because no adequate basis was shown for fixing turnover at more than double the immediately preceding accepted figure. The matter was remanded for fresh determination after giving the assessee an opportunity to place relevant material on record, and the request for enhancement was rejected.

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Issues: Whether the fixation of taxable turnover by the Tribunal for the assessment year 1986-87 was arbitrary and unsustainable, warranting interference and remand.

Analysis: In best judgment assessment, turnover must be fixed on cogent material and rational considerations, and not on conjecture or mere imagination. A short survey of sales during a few hours could not justify extrapolation of sales for full working hours across the year, particularly for perishable consumable goods whose sale pattern depends on market realities. The past assessment history was also a relevant factor and could not be ignored while making a reasonable estimate. As no adequate basis was shown for fixing turnover at more than double the immediately preceding accepted figure, the Tribunal's estimate suffered from arbitrariness. The proper course was to remit the matter to the Tribunal for fresh determination after giving the assessee an opportunity to place relevant material on record.

Conclusion: The turnover fixation was held unsustainable and the matter was remanded to the Tribunal for fresh hearing and decision; the connected request for enhancement was rejected.

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