Cardamom yield estimation must be reasoned and evidence-based when departing from applicable cultivation guidelines.

Assessment of cardamom yield based on plant age-groups was found arbitrary because it was made without inspection of the assessee's property and without a reasoned consideration of the applicable Board guidelines and other relevant material. The guidelines, though not conclusive, were relevant and required consideration, especially as they indicated a substantial fall in yield from the tenth year and replanting by the twelfth year. The revisional authority also failed to independently support the estimate for older plants with material on record. The revisional order was quashed and the matter remitted for fresh disposal, with liberty to justify any departure from the guidelines on proper material.

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Issues: Whether the assessment of cardamom yield on the basis of age-groups of plants was arbitrary and unsustainable for failure to consider the applicable guidelines and relevant material.

Analysis: The assessment accepted yield estimates for plants of different ages without inspection of the assessee's property and without explaining why the Board's guidelines, which indicated a substantial reduction in yield from the tenth year and replanting by the twelfth year, were not followed. The revisional authority also failed to independently address whether the estimated yield for older plants had any supporting material. The guidelines were not conclusive, but they were relevant and had to be considered, and any departure from them required a reasoned basis supported by material.

Conclusion: The yield estimate was held to be arbitrary and unsustainable. The revisional order was quashed and the matter was remitted for fresh disposal according to law, with liberty to the authorities to justify any departure from the guidelines by proper material.

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