Estimation of turnover as a factual exercise barred revision where no legal infirmity in Tribunal findings was shown

Where books of account were not maintained and only loose papers emerged in survey, estimation of turnover and consequent tax liability was treated as a factual exercise. The Tribunal, as final fact-finding authority, reappreciated the material and enhanced turnover on fresh estimation. As no legal infirmity in that factual determination was shown, no question of law arose for revision and interference was not warranted.

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Issues: Whether the Tribunal's estimate of turnover and consequent tax liability raised any question of law warranting interference in revision.

Analysis: The books of account were not maintained, only loose papers were found in the survey, and the assessee had not disclosed taxable turnover. In such circumstances, estimation of turnover was a factual exercise. The Tribunal, being the final fact-finding authority, had reappreciated the material and enhanced the turnover and tax liability on fresh estimation. No legal infirmity was shown in that factual determination.

Conclusion: The issue was decided against the assessee. No question of law arose from the Tribunal's order, and interference in revision was not warranted.

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