Valid reassessment and best judgment assessment sustained where no return or supporting business records were filed for cash deposits.

Reassessment under section 147 was treated as validly initiated where the assessee did not file a return and the material furnished before the Assessing Officer was found unsatisfactory. As no particulars of business turnover, sales, purchases or business expenses were produced before the first appellate authority or the Tribunal, the reassessment procedure, including the order under section 148A(d) and notice under section 148, was held to have been followed in accordance with law. In the absence of any return in response to the notice, the Assessing Officer was justified in making a best judgment assessment under section 144, and the addition relating to cash deposits was not disturbed.

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Issues: Whether the reassessment proceedings under section 147 of the Income-tax Act, 1961 were validly initiated and whether the addition made on account of cash deposits could be disturbed in the absence of any material supporting the assessee's claim of business turnover.

Analysis: The assessee did not file a return of income and the material furnished before the Assessing Officer was found unsatisfactory. No particulars of business turnover, sales, purchases or business expenses were produced either before the first appellate authority or before the Tribunal. The reassessment procedure was held to have been followed in accordance with law, including the order under section 148A(d) and notice under section 148. Since no return was filed in response to the notice, the Assessing Officer was justified in making a best judgment assessment under section 144.

Conclusion: The challenge to the assumption of jurisdiction failed and the addition was not disturbed. The appeal was dismissed.

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