Best judgment assessment must rest on relevant material and disclosed reasoning, not conjecture or ignored explanations.

A best judgment assessment of brick turnover is valid only when based on an honest estimate drawn from relevant facts, the assessee's explanation, and the materials before the assessing authority. The basis of estimation must be disclosed, and the assessment cannot rest on surmises, suspicions, conjecture, or unsupported assumptions. Where books, bills, and explanations are produced, they cannot be ignored merely because the manufacturing accounts are said to be imperfect. An assessment supported by inconsistent reasons and without proper examination of the actual material is not a proper exercise of best judgment. The assessment was held unjustified and the revision succeeded for the assessee.

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Issues: Whether the best judgment assessment made in respect of the petitioner's turnover of bricks was justified in law.

Analysis: A best judgment assessment must be founded on an honest estimate based on relevant facts and circumstances, including the assessee's explanation and the materials placed before the assessing authority. The basis of estimation should be disclosed and should not rest on surmises, suspicions, conjectures, or unsupported assumptions. Where the assessee produces books, bills, and explanations, those materials cannot be ignored merely because the statutory manufacturing accounts are alleged to be imperfect. An assessment supported by inconsistent reasons at different stages, without proper examination of the actual bills and explanations, cannot be sustained as a proper exercise of best judgment.

Conclusion: The best judgment assessment was not justified and the revision petition succeeded in favour of the assessee.

Ratio Decidendi: A best judgment assessment is valid only when it is made on relevant material, with due consideration of the assessee's explanation, and is not based on arbitrary or conjectural estimation.

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