Turnover estimation in an unorganised cash-based recycling business was reduced after no comparable instances supported the higher rate.

The reopening ground was not pressed and therefore did not survive for adjudication. On the merits, turnover in a waste paper recycling business operating in an unorganised, cash-based sector was estimated at 20% by the lower authorities, but the estimate was reduced to 5% because the purchases were not shown to be unexplained and no concrete comparable instances justified the higher rate. The issue was thus decided in favour of the assessee.

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Issues: Whether the turnover of the assessee's waste paper recycling business, estimated by the lower authorities at 20%, required reduction to 5%.

Analysis: The reopening ground was not pressed and did not survive for adjudication. On the merits, the assessment was based on estimation of turnover in a business operating in an unorganised sector. The purchases were not shown to be unexplained, the nature of the business involved cash-based dealings, and no concrete comparable instances were brought on record to justify the higher rate adopted below.

Conclusion: The estimated turnover rate was reduced from 20% to 5% and the issue was decided in favour of the assessee.

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