Turnover estimation based on factual findings does not raise a substantial question of law in revision.

Estimation of turnover based on a best-judgment assessment will not justify revisional interference where it rests on factual appreciation of survey findings, stock discrepancies, absence of proper books of account, and non-filing of required forms. The first appellate authority and the Tribunal accepted a revised turnover estimate after examining the record, and such findings were treated as questions of fact. No substantial question of law arose from that factual assessment, so the Tribunal's order sustaining the reduced tax liability required no interference.

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Issues: Whether the Tribunal's order sustaining estimation of turnover and reduction of tax liability called for interference in revision.

Analysis: The assessment was based on best judgment after survey revealed discrepancies in stock, absence of proper books of account, and non-filing of requisite forms. The first appellate authority and the Tribunal examined the material and accepted a revised estimate of turnover. Estimation of turnover is a question of fact, and no substantial question of law arises where the finding is based on appreciation of facts and accounts.

Conclusion: No interference was warranted with the Tribunal's order, and the revision was liable to be dismissed.

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