Turnover estimation by electricity consumption cannot be revised without adequate material showing the appellate estimate is irrational.

A revisional authority cannot disturb a turnover estimate based on electricity consumption unless the record contains adequate contemporaneous material showing that the appellate estimate is irrational or unsupported. In this crusher-unit dispute, the first appellate authority's higher consumption norm was based on operational factors such as voltage fluctuation, machinery wear, varying boulder hardness and repeated feeding of oversized material, making its estimate more rational. The revision relied mainly on arithmetic from consumption details and earlier survey results, but no relevant assessment-year material justified reopening the appellate finding. The revisional re-fixation of turnover was therefore not sustainable, and the appellate determination was restored.

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Issues: Whether the revisional authority was justified in interfering with the first appellate authority's estimation of turnover on the basis of electricity consumption and whether the revisional order was supported by adequate material.

Analysis: The turnover was estimated from electricity consumption in a crusher unit. The first appellate authority had taken into account factors such as voltage fluctuation, wear and tear of machinery, varying hardness of boulders and repeated feeding of oversized jelly, and on that basis adopted a higher electricity consumption norm than the assessing authority. The revisional authority, while invoking suo motu revision under section 34 of the Tamil Nadu General Sales Tax Act, 1959, relied mainly on arithmetical calculations from the assessee's consumption details and the earlier survey results. The record did not disclose any contemporaneous material from the relevant assessment year to justify upsetting the appellate order. The revisional order was found to be based on insufficient material, whereas the appellate authority's approach was considered more rational and better supported.

Conclusion: The revisional order was not sustainable and the order of the first appellate authority was restored.

Final Conclusion: The turnover re-fixation made in revision could not be sustained for want of adequate supporting material, and the assessee succeeded in having the appellate determination reinstated.

Ratio Decidendi: A revisional authority cannot substitute its own turnover estimate based merely on arithmetic derived from electricity consumption unless the record contains sufficient material showing that the appellate authority's estimate is unsupported or irrational.

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