Best judgment assessment survives a revised return when records show a pattern of suppression and repeated omissions.

A revised return filed after compounding of detected suppression does not automatically bar best judgment assessment under the Kerala Value Added Tax Act. Section 22(10) deems assessment completed on filing the revised return, but that deeming effect remains subject to the powers preserved by sections 24 and 25. Where the record shows a pattern of repeated suppression, the Assessing Authority may still estimate turnover to cover probable omissions. On the stated facts, multiple diaries revealed continuing suppression, so estimation was justified despite the revised return.

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Issues: Whether, after compounding of detected suppression and filing of a revised return under section 22(10) of the Kerala Value Added Tax Act, 2003, the Assessing Authority can still make a best judgment assessment and estimate turnover where a pattern of suppression is found.

Analysis: Section 22(10) deems assessment to be completed on filing of the revised return after finalisation of compounding proceedings, but the provision is expressly subject to sections 24 and 25. The proviso to section 22(10) preserves the power of best judgment assessment where a pattern of suppression is detected. The deeming fiction is meant to regularise the assessment and prevent the original defective return from standing in the way of completion, but it does not divest the Assessing Authority of the statutory power to estimate turnover when the facts disclose repeated suppression. A narrow reading that confines the proviso only to further suppression would render it redundant. On the facts, the recovery of multiple diaries showing repeated suppression over the relevant period established a definite pattern of suppression, justifying estimation to cover probable omissions and suppressions.

Conclusion: The Assessing Authority was entitled to resort to best judgment assessment and estimation notwithstanding the revised return, and the review petition failed.

Ratio Decidendi: A revised return filed after compounding of detected suppression does not oust best judgment assessment where the record shows a pattern of suppression, because the deeming completion under section 22(10) is subject to the reopening and estimation powers preserved by sections 24 and 25.

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