Manufacturing account non-maintenance justified rejection of books and best judgment turnover assessment under trade tax law.

Non-maintenance of the manufacturing account required under the U.P. Trade Tax Act, 1948 rendered the manufacturer's books unreliable because a stock register or equivalent manufacturing record is necessary to verify correctness and maintain a quantitative tally. Prior acceptance of the books in earlier years did not create a right to acceptance for the years in issue. On that basis, rejection of the books was justified, and once rejected, the assessing authority could validly determine turnover on a best judgment basis.

---

---

Issues: Whether the books of account of a manufacturer could be accepted despite non-maintenance of the manufacturing account required under the U.P. Trade Tax Act, 1948, and whether the turnover could be determined by best judgment assessment.

Analysis: The manufacturer had not maintained the manufacturing account in accordance with section 12(2) of the Act. The previous acceptance of the books in earlier years did not create a right to acceptance for the years in question. Relying on the settled principle that a stock register or manufacturing account is essential for verifying the correctness of the accounts and ensuring a quantitative tally, non-maintenance of such account rendered the books unreliable and justified their rejection. Once the books were rejected, estimation of turnover by the assessing authority on best judgment basis was held to be proper.

Conclusion: The rejection of the books of account and the best judgment assessment were upheld, and the revisions failed.

---