Best judgment assessment upheld where undisclosed sales justified rejection of books and year-wide turnover additions.

Undisclosed sales proved to be outside the books of account required rejection of the accounts as a necessary consequence and justified best judgment assessment, because the suppression showed that the recorded books did not reflect true turnover. The fact that the discrepancy was detected for only one month did not prevent the authority from sustaining additions for the full year, as similar suppression could reasonably be inferred in other months as well. Concurrent findings on concealed sales and the need for best judgment assessment raised no substantial question of law, and the challenge failed.

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Issues: Whether the best judgment assessment made on the basis of undisclosed sales was invalid for want of prior rejection of books of account, and whether the additions made for the full year could be sustained when the discrepancy was noticed for only one month.

Analysis: The undisclosed sales were found outside the books of account and that factual position was not disputed. Once sales outside the books were established, rejection of the books of account followed as a necessary consequence. The authority was justified in resorting to best judgment assessment because the suppression of sales showed that the accounts did not present the true turnover. The circumstance that the detected concealment related to one month did not preclude the inference that similar suppression could have occurred in other months as well. No substantial question of law arose from the concurrent findings of the authorities below.

Conclusion: The challenge to the best judgment assessment failed and the finding sustaining addition to turnover was upheld in favour of the Revenue.

Final Conclusion: The appeal was dismissed since the concurrent findings on concealed sales and best judgment assessment disclosed no substantial question of law.

Ratio Decidendi: Proof of sales outside the books of account makes rejection of the accounts a necessary consequence and permits best judgment assessment on the basis that the suppression may have extended beyond the specific period detected.

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