Estimation of turnover is a question of fact, limiting revision to legal issues under trade tax law.

Estimation of turnover after rejection of a dealer's books of account is treated as a question of fact, not a question of law. Where the assessment, first appeal, and Tribunal all rest on estimation, revisional interference under section 11 of the U.P. Trade Tax Act, 1948 is confined to legal issues and does not permit reappreciation of factual findings. On that basis, no question of law arose for interference in revision, and the issue was decided against the assessee.

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Issues: Whether an assessment based on estimation after rejection of the dealer's books of account gives rise to a question of law fit for interference in revision under section 11 of the U.P. Trade Tax Act, 1948.

Analysis: The assessment, the first appellate order, and the Tribunal's order were all founded on estimation. The governing principle applied was that estimation of turnover is a question of fact and not a question of law. Revisional interference under section 11 of the U.P. Trade Tax Act, 1948 is confined to questions of law, and the court cannot reappreciate factual findings when no legal issue arises from the Tribunal's order.

Conclusion: The issue was answered against the assessee. No question of law arose for interference in revision.

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