Factual income estimation based on evidence upheld where the Tribunal gave adequate reasons for reducing daily receipts.

The Tribunal's income estimate was treated as a factual determination based on the material on record, including the number of working days and receipt per day. Its reduction of the estimated daily receipt was supported by adequate reasons and was not shown to be perverse or based on surmise. As the issue concerned a factual estimate for the relevant year, no interference was warranted in reference jurisdiction and no reference was called for.

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Issues: Whether the Tribunal's estimate of the assessee's income, based on the number of working days and receipt per day, called for interference in reference jurisdiction.

Analysis: The Tribunal had reduced the estimated receipt per day on the basis of material on record and recorded adequate reasons for doing so. The finding was treated as an inference from the facts available and not as one based on surmises. The question was one of factual estimate of income for the relevant year.

Conclusion: The Tribunal's estimate was upheld as a fair factual estimate, and no reference was called for.

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