Best judgment turnover estimation upheld where rejected account books showed stock discrepancies and unreliable records.

Revisional interference was declined where the dealer's account books were rejected on survey-based evidence, including stock discrepancies, pencil entries capable of alteration, absence of a coal stock register despite coal consumption, and irregularities in the RGI register. On that basis, the authorities' staged best judgment estimation of taxable turnover was sustained, and the Tribunal's reasons for reducing the estimate and refusing enhancement were accepted. The Court held that, in revision, it would not substitute its own turnover estimate where the findings rested on appreciation of evidence and no material established any fixed cap on turnover.

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Issues: Whether the rejection of the dealer's account books and the consequent best judgment estimation of taxable turnover called for interference in revision.

Analysis: The account books were rejected on the basis of material found during survey, including stock discrepancies, use of pencil entries permitting alteration, absence of a coal stock register despite consumption of coal, and irregularities in the RGI register. After rejection of the books, the authorities made a staged best judgment assessment on relevant facts and circumstances. The Tribunal also gave reasons for reducing the estimate and for declining enhancement. In revisional jurisdiction, the Court would not substitute its own estimate of turnover where the findings rested on appreciation of evidence and no material was shown to cap the turnover at any particular figure.

Conclusion: The rejection of account books and the estimated turnover were upheld, and no interference was warranted.

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