Best judgment assessment permits rejection of unproved processing expenses and computation of input value on reasonable available material.

In best judgment assessment under the Trade Tax Act, the authorities accepted the dealer's sales turnover but, because no supporting records or material evidence were produced, rejected the claim for deduction of alleged chemical treatment and ozonisation expenses. The dealer also failed to establish the claimed wheat purchases and the composition of the goods. On that basis, the purchase value of wheat was computed on an average sale price using reasonable available material, and the assessment was found free from illegality, infirmity, or perversity. The computation and rejection of the expense claim were upheld.

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Issues: Whether the authorities were justified in computing the purchase value of wheat on the basis of an average sale price and in rejecting the dealer's claim for deduction of alleged chemical treatment and ozonisation expenses for want of proof.

Analysis: The assessment arose from best judgment proceedings under Section 3G of the Trade Tax Act, 1948. The dealer claimed that the flour products were chemically treated and ozonised and that substantial expenditure had been incurred for that purpose, but no supporting documents, records, or material evidence was produced before the assessing authority, the first appellate authority, or the Tribunal. The dealer also failed to establish the alleged purchase of wheat and the claimed composition of the goods. In these circumstances, the authorities accepted the sales turnover but determined the wheat purchase value on an average rate and rejected the claimed chemical treatment expenses. The challenge to the assessment did not disclose any illegality, infirmity, or perversity.

Conclusion: The computation adopted by the authorities was upheld and the dealer's claim was rejected.

Ratio Decidendi: In the absence of proof, a dealer's unsubstantiated claim of higher input cost or special processing expenses can be rejected in best judgment assessment, and the purchase value may be determined on the basis of reasonable available material.

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