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Issues: Whether the turnover of rice could be enhanced by rejecting the selling rate disclosed by the dealer in the absence of material showing the prevalent market rate or any defect in the maintained account books.
Analysis: The dealer had maintained the account books required by law and no discrepancy was found in them. The authorities enhanced the sale rate mainly on the assumption that the opening stock valued at a higher rate must have contained rice of all qualities, without recording any finding on the prevailing market rate or producing material to rebut the dealer's explanation and supporting affidavit. The record also showed substantial sales to the Food Corporation of India at higher rates, and the explanation that different qualities of rice fetched different prices was consistent with the nature of the business and the seasonal fall in price after the arrival of the new crop. In revisional jurisdiction, an enhancement based only on conjecture, without evidentiary foundation, could not be sustained.
Conclusion: The enhancement of turnover and the rejection of the disclosed selling rate were unjustified. The revision succeeded and the dealer's declared turnover was accepted.
Ratio Decidendi: A disclosed sale rate cannot be rejected and turnover cannot be enhanced merely on conjecture when the account books are accepted, no defect is found, and no material is brought to show a higher prevailing market rate.