Turnover estimation must consider past assessment history, and a higher reassessment cannot stand without addressing the lower authority's reasoning.

In turnover-estimation disputes under the U.P. Sales Tax Act, past assessment history is a relevant factor, and an appellate authority reversing a reduced estimate should address the basis relied on by the lower authority. Here, the first appellate authority had reduced the assessed turnover by considering the assessee's prior year assessment, but the Tribunal restored the higher figure without properly meeting that reasoning. The restoration could not be sustained, and the revision succeeded partly in favour of the assessee.

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Issues: Whether the Sales Tax Tribunal was justified in restoring the assessed turnover at a higher figure without dealing with the basis on which the first appellate authority had reduced the estimate.

Analysis: The revision arose from an assessment under the U. P. Sales Tax Act for a year in which the assessee dealt in electrical goods. The account books had been rejected and the turnover estimated by the assessing authority, but the first appellate authority reduced the estimate after taking into account the turnover assessed in the immediately preceding year. In reversing that order, the Tribunal stated that no basis had been given for the reduction, but the record showed that the earlier assessment history had in fact been considered. In estimation matters, the past history of the assessee is a relevant factor, and an authority reversing a lower order is expected to meet the reason that persuaded the lower authority.

Conclusion: The Tribunal's order restoring the higher assessed turnover could not be sustained, and the revision succeeded partly in favour of the assessee.

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