Sales return deduction must be claimed in the original assessment year, with reopening permitted if statutory conditions are met.

Sales return deduction is allowable only in the assessment year in which the corresponding sales were included in turnover, not in the succeeding year. Where the assessee satisfies the statutory time limits, account entries, and claim requirements, a completed assessment for the correct year may be reopened so the deduction can be examined on merits and the assessment revised accordingly. A mistaken claim in the later year does not change the legal position. The impugned revision was set aside and the assessing authority was directed to reopen the earlier year and decide the deduction claim in accordance with law.

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Issues: Whether deduction in respect of sales returns is allowable only in the assessment year in which the returned goods were originally sold, and whether, if the assessment for that year is already completed, the assessment can be reopened to grant the deduction.

Analysis: The applicable rules permitted deduction for amounts allowed to purchasers on account of returned goods only if the goods were returned within the prescribed time and the necessary account entries and claim requirements were satisfied. The deduction had to be given from the turnover of the assessment year in which the returned goods were sold, and not from the turnover of the succeeding year. The fact that the assessee had mistakenly claimed the benefit in the later year did not alter the legal position. Where the claim was otherwise in time and in order, the completed assessment for the correct year could be reopened so that the deduction could be considered on merits and the assessment revised accordingly.

Conclusion: The deduction could not be claimed in the succeeding assessment year, but the assessment for the correct year could be reopened to consider the claim if the statutory requirements were satisfied. The assessee succeeded.

Final Conclusion: The impugned revision was set aside and the assessing authority was directed to reopen the earlier assessment year and decide the sales return deduction claim in accordance with law.

Ratio Decidendi: A sales return deduction is allowable only in the assessment year in which the corresponding sales were included in turnover, and a completed assessment for that year may be reopened to grant the deduction if the statutory conditions and time limits are fulfilled.

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