Reliability of accounts and comparable-estate estimation sustained where agricultural records lacked credibility and no error of law was shown.

Rejection of agricultural income accounts was sustained because the books of account and crop register were found unreliable, having been prepared at a stretch and not maintained in the regular course of business. The assessee failed to explain the sharp fall in yield or to produce satisfactory evidence for the claimed expenses, and the slaughter-tapping agreement was treated as doubtful because it was unregistered, undated on stamp paper, and not produced during inspection. In these circumstances, the authorities were entitled to estimate income by reference to comparable nearby estates, and the High Court held that these factual findings disclosed no error of law warranting revision.

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Issues: Whether the rejection of the assessee's books of account and crop register, and the estimation of agricultural income on the basis of comparable cases, called for interference in revision under section 78.

Analysis: The accounts were found not to have been kept in the regular course of business, with the books and crop register written at a stretch and the authenticity of the records open to doubt. The yield declared was substantially lower than earlier years, and no satisfactory explanation or supporting evidence was produced for the claimed expenses and the steep fall in income. The agreement relied on for slaughter tapping was found unreliable, being unregistered, lacking a recorded stamp-paper date, and not produced at the time of inspection. The authorities therefore relied on nearby comparable estates to estimate the value of the trees and latex. These findings were factual, supported by material, and disclosed no error of law.

Conclusion: The rejection of accounts and the estimation of income were upheld, and no interference was warranted in revision.

Ratio Decidendi: Findings on the reliability of accounts and the appropriate estimate of income, when based on cogent material and comparable instances, are essentially findings of fact and do not justify revision absent an error of law.

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