Best judgment reassessment sustained where no reply or supporting evidence rebutted the investment explanation.

A reassessment under section 148 was issued to an HUF after no reply or explanation was filed. The challenge to the Tribunal's endorsement of the ex parte best judgment assessment failed because no material was produced to support the claim that the investment came from loans. The Tribunal was entitled to rely on the probabilities of the case and the absence of contrary evidence, and its finding was not shown to be perverse or based on no evidence. No interference was called for.

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Issues: Whether the Tribunal's finding upholding the reassessment and ex parte best judgment assessment was perverse or based on no evidence.

Analysis: Notice under section 148 of the Income-tax Act was issued to the Hindu undivided family, but no reply or explanation was filed. The appeals were pursued without any material to support the claim that the investment had been made out of loans. In these circumstances, the Tribunal relied on the probabilities of the case and the absence of contrary evidence to uphold the assessment.

Conclusion: The finding was not shown to be perverse or based on no evidence, and no interference was called for.

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