Turnover estimation requires adverse material for the relevant year; later-year evidence cannot justify an addition.

Estimated enhancement of coal dust turnover for the relevant assessment year was not sustainable because the record disclosed no adverse material showing concealment or suppression. The assessing authority itself found no attempt to conceal turnover, and an enquiry report relating to a different year could not justify addition for the year in issue. As each assessment year is a separate unit, material from a later year could not be used to support estimation for the earlier year. The addition beyond the admitted turnover was therefore set aside, and tax liability was confined to the disclosed turnover for that assessment year.

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Issues: Whether the estimated enhancement of turnover of coal dust for assessment year 1994-95 could be sustained in the absence of adverse material showing concealment or suppression.

Analysis: The assessment records did not reveal any adverse material against the disclosed turnover of coal dust. The assessing authority itself found no attempt to conceal turnover, and the subsequent enquiry report related to a different assessment year and could not justify addition for the relevant year. Since each assessment year is a separate unit, material from a later year could not be used to support estimation for the year in question.

Conclusion: The enhancement of turnover of coal dust was not justified and the addition beyond the admitted turnover was set aside in favour of the assessee.

Final Conclusion: The revision was partly allowed and tax liability was confined to the admitted turnover of coal dust for the relevant assessment year.

Ratio Decidendi: In the absence of adverse material showing concealment or suppression for the relevant assessment year, turnover cannot be estimated merely on the basis of material pertaining to a different year.

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