Best-judgment assessment allows estimated deductions beyond the return figure when the return has been rejected.

After rejection of an assessee's return and resort to best-judgment assessment, the assessing authority may estimate both gross agricultural income and allowable deductions on the same footing. The deduction figure stated in the return is only an evidentiary admission and is not binding once the return has been rejected. There is no statutory bar on allowing a larger cultivation expense deduction if the available materials and best judgment support it, and estoppel does not prevent the assessee from obtaining that larger allowance. The authority is therefore not confined to the deduction claimed in the return.

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Issues: Whether, after rejecting an assessee's return and making an assessment under the best-judgment procedure, the assessing authority can allow a deduction for cultivation expenses greater than the amount claimed in the return and is bound by the return figure.

Analysis: Under the statutory scheme, the total agricultural income is determined by estimating the gross income and the permissible deductions. Where the return is rejected and the assessing authority proceeds under the best-judgment power, the same method applies both to gross receipts and to deductions. The deduction figure stated in the return is only an admission and is not conclusive; it may be disbelieved or treated as incorrect. The return does not bind the authority once it has been rejected, and there is no statutory restriction preventing allowance of a higher deduction if that is what the authority, on the available materials and best judgment, considers proper. The doctrine of estoppel does not prevent the assessee from obtaining a larger deduction in such assessment proceedings.

Conclusion: The assessing authority may, under the best-judgment assessment provision, allow a larger deduction than that claimed in the rejected return and is not bound by the deduction figure stated by the assessee.

Ratio Decidendi: In a best-judgment assessment after rejection of a return, permissible deductions are also to be estimated on the same footing as gross income, and the amount shown in the return is only evidentiary, not binding.

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