Rejected books and estimated additions upheld in brick kiln assessment; absence of reliable records defeated challenge to findings.

In brick kiln assessment, rejection of the books of account was treated as proper where the assessee maintained no reliable books, no labour register, and no coal consumption register to verify firing period or kiln capacity. On that factual record, estimation of production and consequent additions based on available material was upheld, and the assessee's own survey disclosure supported the capacity adopted by the authorities. The Court treated estimation as a question of fact, found no perversity in the concurrent findings below, and held that no substantial question of law arose.

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Issues: Whether the assessing authority was justified in rejecting the books of account and making estimation-based additions in the brick kiln business, and whether any substantial question of law arose from the Tribunal's order.

Analysis: The assessee maintained no proper books of account, no labour register, and no coal consumption register to establish the firing period or the actual capacity of the brick kiln. The assessee's own disclosure at the time of survey supported the capacity adopted by the authorities. In these circumstances, rejection of the books and estimation of production and additions on the basis of available material was held to be proper. Estimation was treated as a question of fact, and the Court found no perversity in the concurrent findings of the authorities below.

Conclusion: The rejection of books of account and the estimation-based additions were upheld. No substantial question of law arose, and the revisions failed.

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