Best judgment assessment cannot rest solely on missing manufacturing accounts without evidence of suppressed turnover.

Mere non-maintenance of manufacturing accounts does not, by itself, justify best judgment enhancement of purchase turnover where the books and stock records do not disclose suppression. The assessee's explanation that fibre glass boats were made against specific customer orders and that item-wise material consumption could not be practically quantified was accepted as plausible. In the absence of material showing concealed turnover, the addition based on presumed suppression could not be sustained, and the Tribunal's deletion of the addition did not call for revisional interference.

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Issues: Whether the assessing authority was justified in estimating the purchase turnover by best judgment assessment merely because the assessee did not maintain manufacturing accounts, and whether the Tribunal's deletion of the addition called for interference in revision.

Analysis: The assessee had maintained the opening and closing stock accounts, and the books produced did not disclose suppression of turnover. The explanation that fibre glass boats were manufactured against specific customer orders and that material consumption could not be feasibly evaluated in each case was found plausible. The absence of manufacturing accounts, by itself, did not establish suppression of purchase turnover or justify an addition based solely on that omission. The Tribunal's view was not shown to be perverse or arbitrary.

Conclusion: The addition made on the hypothesis of suppression could not be sustained, and no ground for revisional interference was made out.

Final Conclusion: The assessee succeeded in retaining the relief granted by the Tribunal, and the revision was rejected.

Ratio Decidendi: Mere non-maintenance of manufacturing accounts, without corresponding material showing suppression of turnover, is insufficient to sustain a best judgment enhancement or warrant revisional interference.

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