Estimation of income is a question of fact, so concurrent findings sustained rejection of books and addition

Estimation based on survey discrepancies and rejection of books of account was treated as a question of fact, and the concurrent findings of the assessing authority, first appellate authority, and Tribunal were supported by the record. On that basis, revisional interference was held unwarranted because no question of law arose. The rejection of the books of account and the estimate-based addition were therefore sustained.

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Issues: Whether the Tribunal was justified in sustaining rejection of the books of account and estimation of addition, and whether any question of law arose for interference in revision.

Analysis: The assessment was based on survey discrepancies found at the business premises, and the assessing authority rejected the books of account and made an estimate-based addition. The first appellate authority examined the material and granted only partial relief, and the Tribunal upheld that approach. The governing principle applied was that estimation is a question of fact, and where the factual findings of the authorities below are supported by the record, no interference in revision is warranted merely because a different view is possible.

Conclusion: The rejection of the books of account and the estimate-based addition were upheld, and no question of law arose for revisional interference.

Final Conclusion: The revision failed and the order of the Tribunal was sustained.

Ratio Decidendi: Estimation based on factual discrepancies found in assessment proceedings is a question of fact, and revisional interference is not called for when concurrent findings are supported by the record and no question of law arises.

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