Best judgment assessment upheld where slaughter tapping and absence of supporting accounts left no basis to disturb concurrent factual findings.

Best judgment assessment was sustained where inspection materials indicated slaughter tapping, engagement of tappers, and no reliable accounts or proof to support the return. The assessee failed to substantiate the alleged tapping arrangement with credible evidence, so the dispute was treated as a factual issue already resolved by the authorities below. In second revision, interference was confined to a narrow scope, and no ground was shown to disturb the concurrent factual findings or the estimate made on best judgment. The challenge therefore failed and the assessment was upheld.

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Issues: Whether the assessment could be interfered with in revision on the ground that the estate was under a slaughter tapping arrangement and that the best judgment assessment was arbitrary.

Analysis: The assessment authority and the revisional authority relied on the inspection report and surrounding materials showing slaughter tapping, engagement of tappers, and the absence of accounts or other proof to support the return. The assessee did not substantiate the alleged tapping agreement with reliable evidence, and the contention was treated as one of fact already concluded by the authorities below. In second revision, the scope of interference was narrow, and no basis was shown to disturb the concurrent factual findings or the estimate made on best judgment.

Conclusion: The challenge to the best judgment assessment failed, and the finding against the assessee was upheld.

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