Reassessment cannot raise turnover again on the same material, while a supported turnover estimate will stand absent error.

Reassessment under section 21 could not justify further turnover enhancement where the same material had already been considered in the original assessments. The article notes that the dealer's business conditions, including the riot-related destruction of the shop and absence of proper account books, were already factored into the original estimates; the timber import information in form XXXI did not warrant additional additions for 1984-85 or 1985-86, so those reassessment additions were set aside. For 1986-87, the turnover fixed on the record was independently supportable and showed no demonstrable error, so it was left undisturbed.

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Issues: (i) Whether reassessment for the assessment years 1984-85 and 1985-86 under section 21 of the Act could be sustained on the basis of the information relating to import of timber through form XXXI; (ii) Whether the turnover fixed for the assessment year 1986-87 required interference.

Issue (i): Whether reassessment for the assessment years 1984-85 and 1985-86 under section 21 of the Act could be sustained on the basis of the information relating to import of timber through form XXXI.

Analysis: The material on record showed that the original assessments had already taken into account the dealer's business circumstances, including the destruction of the shop in the riot and the absence of proper account books. For the assessment year 1984-85, the information regarding import of timber through form XXXI for Rs. 17,160 had already been effectively reflected in the original estimation of turnover, and no further enhancement was justified in reassessment. For the assessment year 1985-86, the reassessment was also founded on the same kind of material and on the earlier year's position, which could not support the higher figure adopted by the authorities in the reassessment proceedings.

Conclusion: The reassessment additions for the assessment years 1984-85 and 1985-86 were not sustainable and were set aside.

Issue (ii): Whether the turnover fixed for the assessment year 1986-87 required interference.

Analysis: For the assessment year 1986-87, the record did not disclose any error in the turnover fixed by the Tribunal. The order for that year was independently supportable on the facts and did not call for modification.

Conclusion: The turnover for the assessment year 1986-87 was upheld and no interference was made.

Final Conclusion: The revisions succeeded in relation to the reassessment years 1984-85 and 1985-86, with partial relief in the latter year, while the revision for 1986-87 failed.

Ratio Decidendi: Reassessment under section 21 cannot be used to make further turnover enhancement on the same material already considered in the original assessment, and a turnover estimate will not be disturbed absent demonstrated error.

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