Estimate-based assessment of brick kiln production raised no substantial question of law where books and records were absent.

Absence of proper books of account and supporting records justified estimate-based additions in assessment of a brick kiln business. The Tribunal's estimate of the burning period and brick production, and the partial restoration of the assessment on the same footing, involved factual appreciation rather than any legal principle. As the record showed no legal infirmity or perversity in the Tribunal's approach, the dispute did not raise a substantial question of law. The revision was therefore not maintainable and the assessee's challenge failed.

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Issues: Whether the Tribunal's estimate of the brick kiln's burning period and brick production, based on absence of proper books of account and supporting records, gave rise to any substantial question of law warranting interference in revision.

Analysis: No proper books of account were found at the time of survey, and such records were neither produced before the authorities below nor before the Tribunal. In these circumstances, the assessing authority was justified in making additions on estimate basis. The first appellate authority had granted partial relief on estimate basis, and the Tribunal partly restored the assessment on the same footing. Estimation of this nature is a question of fact, and the record did not disclose any legal infirmity or perversity in the Tribunal's approach. Since the controversy turned entirely on factual appreciation and estimation, no substantial question of law arose.

Conclusion: The revision was not maintainable on any substantial question of law and the assessee's challenge failed.

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