{"id":7170,"date":"1998-05-27T00:00:00","date_gmt":"1998-05-26T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/deepak-industries-vs-salex-tax-officer-new-delhi-ors-on-27-may-1998"},"modified":"2017-02-01T15:10:44","modified_gmt":"2017-02-01T09:40:44","slug":"deepak-industries-vs-salex-tax-officer-new-delhi-ors-on-27-may-1998","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/deepak-industries-vs-salex-tax-officer-new-delhi-ors-on-27-may-1998","title":{"rendered":"Deepak Industries vs Salex Tax Officer, New Delhi & Ors. on 27 May, 1998"},"content":{"rendered":"
Delhi High Court<\/div>\n
Deepak Industries vs Salex Tax Officer, New Delhi & Ors. on 27 May, 1998<\/div>\n
Equivalent citations: 1998 IVAD Delhi 753, 73 (1998) DLT 719, 1998 (46) DRJ 208<\/div>\n
Author: R Lahoti<\/div>\n
Bench: R Lahoti, M Mudgal<\/div>\n<\/p>\n
<\/pre>\n
JUDGMENT<\/p>\n
 R.C. Lahoti, J. <\/p>\n
 1.     The  petitioner is engaged in the business of building of bus  bodies. It  is  a  dealer registered under the Delhi Sales Tax Act,  1975  and  the Central  Sales  Tax  Act, 1956. For the period of  assessment  1983-84  the
\nreturns  were filed on 22.3.88. At the time of assessment, the  dealer  did not produce cash book and purchase vouchers. The Assessing Officer discarded  the  figure of sales as returned and proceeded to  make  best  judgment assessment.\n<\/p>\n
 2.   As  per returns the total turnover was Rs. 56,95,150\/-. The  Assessing Officer  took the year 1982-83 as the basis for assessment, in  which  year the  figure of total turnover was Rs. 98,52,500\/-. The  Assessment  Officer determined the total turnover for 1983-84 at Rs. 1,25,00,000\/-.\n<\/p>\n
 2.1. The  relevant part of the order of assessment under the Local  Act  is extracted and reproduced hereunder:\n<\/p>\n
      In response to ST 13, Shri Anil Verma, Advocate appeared for the  last time  with the aforesaid books on 29.3.88. The dealer did not produce  cash book.  When purchase vouchers were demanded from the dealer, the same  were also not produced. One purchase voucher which is for Rs. 17,181.15 was also not entered in the books. Hence the sales disclosed in the returns are  not acceptable.\n<\/p>\n
      As  per returns the total turnover comes to Rs. 56,95,150\/-. The  same is not acceptable in the absence of books\/purchase invoices. Hence  1982-83 is regarded as the basis for assessment. In 1982-83 total turnover was  Rs.\n<\/p>\n
98,52,500\/-.  Hence  for  this year total turnover  is  determined  as  Rs. 1,25,00,000\/-,  ail local sale is taxable @ 10%, hence there being  no  adverse material, assessment is as under:\n<\/p>\n
      G.T.O.         1,25,00,000\/-I.S.S.           50,55,050\/-\n     Taxable 10%      74,44,950\/-\n     Tax assessed      7,44,495\/-\n \n\n 2.2. The Assessing Officer also imposed a penalty of Rs. 5,000\/- and interest Rs. 44,639\/-. \n \n\n 2.3. Assessment order was framed under the Central Act as under: \n      Tax @ 10% \n     under the \n     Central Act    5,05,505\/-\n     Penalty           5,000\/-\n     Interest       1,41,541\/-\n \n\n 2.4. Thus  a  demand  of  Rs. 7,94,134\/- under the Delhi  Act  and  of  Rs. \n6,52,046\/- under the Central Act were created. \n \n\n<\/pre>\n
 2.5. The  assessee  preferred revision petitions which were  dismissed.  An application seeking review of the revisional orders was also dismissed.\n<\/p>\n
 3.   Aggrieved petitioner has approached this Court under Articles  226\/227 of the Constitution of India.\n<\/p>\n
 4.   Two  submissions have been made by the learned Counsel for  the  petitioner  at the time of hearing. Firstly, it is submitted that a best  judgment assessment cannot be a wild assessment; and secondly, the interest  on tax cannot be charged under the Central Act. On these grounds the orders of assessment  and the orders in revision and review confirming the  same  are sought to be set aside.\n<\/p>\n
 5.   During  the  course of hearing Mr. S.K. Dholakia, the  learned  Senior Counsel  for the petitioner pointed that for the years preceding  and  succeeding  the year in question the turnover of the petitioner  assessee  has been assessed as under:\n<\/p>\n
                              DEEPAK INDUSTRIES<\/p>\n
     A.Yr.     Turnover                Remarks
\n     (Rs.)     assessed
\n     1980-81   39,13,855           Assessment framed as
\n                                   per books of accounts.\n<\/p><\/blockquote>\n
     1981-82   97,79,550           Assessment framed on \n                                   the basis of sales \n                                   figures given by the \n                                   petitioner at the \n                                   time of assessment. \n                                   Book version of \n                                   sales accepted.\n     1982-83   98,52,500           Assessment framed on \n                                   the basis of sales \n                                   figure given by the \n                                   petitioner to the \n                                   Sales Tax officials \n                                   on 6.4.83. Sales \n                                   enhanced by \n                                   Rs. 10,000\/- per \n                                   quarter only.\n     1983-84   1,25,00,000         Turnover enhanced by \n                                   Rs. 70,00,000\/-.\n                           (THE YEAR OF DISPUTE)\n     1984-85   33,29,445           Book version of \n                                   sales accepted.\n     1985-86   34,31,769           Book version of \n                                   sales accepted.\n     1986-87   -                   Business closed down. \n                                   RC surrendered for \n                                   cancellation.\n \n\n      The  above said factual position is not disputed on behalf of  the  respondents. \n \n\n<\/pre>\n
 6.   By  reference to the copy of order sheets, showing the record of  proceedings  before the Assessment Officer filed as Annexure P-1, the  learned Counsel  for the petitioner pointed out that several dates of hearing  were appointed between 22.4.87 and 15.3.88, but the Assessing Officer did  nothing  to  make any progress in the matter of assessment. The  hearings  were simply  adjourned. However, since 15.3.88, the Assessing  Officer  suddenly swung into swift action possibly foreseeing the time barring date approaching  fast.  On 24.3.88, the ASTO who was dealing with the matter  sent  the same  to  the STO, the case being ‘A – category case’ which  only  the  STO could  deal  with. Before the STO the petitioner appeared  on  25.3.88  and without  affording an adequate opportunity of hearing and participation  in the assessment proceedings, the same were hurriedly closed. However, we  do not  deem it necessary to enter into and adjudicate upon this part  of  the controversy  as the impugned order of assessment, in our opinion is  liable to be set aside on other grounds as stated hereinafter.\n<\/p><\/blockquote>\n
 7.   The  leading  authority on the principles relevant  to  best  judgment assessment  is  the Privy Council decision in Commissioner of  Income  Tax, Central and United Provinces Vs. Lakshmi Narain Badri Dass, (1937) (5)  ITR 170,180, their Lordships have held:\n<\/p>\n
       “He  (the Assessing Authority) must not act dishonestly, or  vindictively  or capriciously because he must exercise  judgment  in the  matter. He must make what he honestly believes to be a  fair estimate of the proper figure of assessment, and for this purpose he  must, their Lordships think, be able to take into  consideration  local  knowledge and repute in regard,  to  the  assessee’s circumstances,  and his own knowledge of previous returns by  and assessments  of  the  assessee, and all other  matters  which  he thinks will assist him in arriving at a fair and proper estimate;  and though there must necessarily be guesswork in the matter,  it must  be  honest guesswork. In that sense, too,  the  assessment  must be to some extent arbitrary.”\n<\/p>\n
 8.   In Raghubar Mandal Harihar Mandal Vs. State of Bihar, ,
\ndealing  with Section 10(2) of Bihar Sales Tax Act, 1944,  their  Lordships have held:\n<\/p>\n
       “The  Assessing Authorities under Section 10(2)(b) are not  entitled,  after rejecting the returns and books of accounts  of  the assessee,  proceed  to estimate the gross turnover  and  made  an assessment  without reference to any evidence or any material  at  all, indulging in pure guess work.”\n<\/p>\n
 9.   In  State  of  Kerala Vs. C. Velukutty, (1966) 17 STC  465  SC,  their Lordships have held :\n<\/p>\n
       “The limits of the power are implicit in the expression “best  of his  judgment.”  Judgment  is a faculty to  decide  matters  with wisdom  truly  and  legally. Judgment does not  depend  upon  the arbitrary  caprice  of  a judge, but on  settled  and  invariable principles of justice. Though there is an element of guesswork in a best judgment assessment, it shall not be a wild one, but shall have a reasonable nexus to the available material and the circumstances of each case. Though subsection (2) of Section 12 of the  Act  provides for a summary method because of the default of  the
\n     assessee, it does not enable the Assessing Authority to  function capriciously without regard for the available material.”\n<\/p>\n
 10.  The  following principles laid down by their Lordships of the  Supreme Court  in State of Orissa Vs. Maharaja Shri B.P. Singh Deo, (1970)  76  ITR 690, though in the context of income tax, are apposite here at also:\n<\/p>\n
       “The  mere fact that the material placed by the  assessee  before the  Assessing Authorities is unreliable does not  empower  those authorities to make an arbitrary order. The power to levy assessment on the basis of best judgment is not an arbitrary power;  it is  an assessment on the basis of best judgment. In other  words, that  assessment must be based on some relevant material.  It  is not a power that can be exercised under the sweet Will and pleasure of the concerned authorities.”\n<\/p>\n
 11.  In  Commissioner  of  Sales Tax, MP Vs. H.M.  Eusfali  H.M.  Abdulali, (1973)  32 STC 77 (SC), their Lordships have held that once  the  Assessing Officer  has found that assessee had dealings outside the accounts then  it was not possible to find out precisely the turnover suppressed and only  an estimate thereof can be made “on the basis of the material before him”.  So long  as the estimate made by the Assessing Officer was not  arbitrary  and had  a  reasonable nexus with the facts discovered, it could not  be  questioned,  though  material  cannot be expected to be  available  before  the
\nAssessing  Officer to prove the exact turnover suppressed. Their  Lordships have further held :\n<\/p>\n
       “In estimating any escaped turnover, it is inevitable that  there is some guesswork. The Assessing Authority while making the  best judgment  assessment, no doubt, should arrive at  his  conclusion without  any bias and on a rational basis. That authority  should not be vindictive or capricious. If the estimate by the Assessing Authority  is  a bona fide estimate and is based  on  a  rational basis,  the fact that there is no good proof in support  of  that estimate  is immaterial. Prima facie, the Assessing Authority  is the best Judge of the situation. It is his best judgment and  not
\n     any  one else’s. The High Court cannot substitute its best  judgment for that of the Assessing uthority.”\n<\/p>\n
 12.  A Division Bench of our own High Court has held in Chowdhary  Chemical Works  Vs.  Commissioner of Sales Tax, New Delhi, (1992) 84 STC  156,  that best  judgment assessment has to be based on some relevant  material  which can be utilised for estimating the gross turnover. An increase of about 15% in  the turnover of a business in the absence of any adverse  circumstances was  considered to be reasonable and fair where two decisions of  Financial Commissioner  were available to support the view that such was  the  normal percentage of increase in turnover in that class of business.\n<\/p>\n
 13.  So  is the view taken by several High Courts of the country [See  Dwijendra  Kumar  Bhattacharjee  Vs. Superintendent of  Taxes,  Government  of Tripura, (1990) 78 STC 393 (Gauhati); Bhagwandas Khandelwal v. The  Commissioner  of Sales Tax, Madhya Pradesh, Indore & Ors, (1971) 27 STC  388  MP; Jhagru  Shah & Ors. Vs. CCT & Ors., 1966 (17) STC 130 (Cal.);  M.  Apukutty Vs.  S.T.O.  Kozhikode, 1966 (17) STC 380 (Kerala)].  In  Dwijtendra  Kumar Bhattacharjee (supra), after rejection of the books of accounts an  assessment  made on “mere guesses and surmises without reference to any  evidence or materials at all” was held to be unsustainable.\n<\/p>\n
 14.  To sum up, the principles governing a best judgment assessment are:\n<\/p>\n
      i)   A best judgment assessment is not a wild assessment.  Exclusion of arbitrariness and caprice is an obligation  implicit in the power to assess to the best of judgment.\n<\/p><\/blockquote>\n
      ii)  Assessment to the best of judgment must be founded upon some rational  basis, relevant material and logic so  that  nexus between such basis or material and the figure of  assessment arrived  at  can be objectively seen though some  amount  of guess work or estimation is to be allowed like a play in the joint.\n<\/p><\/blockquote>\n
      iii) It  is  not necessary that evidence in the  nature  of  good proof  should  be available on record to support  the  estimates.\n<\/p><\/blockquote>\n
      iv)  Power to make best judgment assessment exercised bona  fide, reasonably and rationally shall not be open to  interference in judicial review.\n<\/p><\/blockquote>\n
 15.  Testing the order of best judgment assessment impugned herein, on  the principles  set  out  hereinabove, it is clear that  having  discarded  the figure of turnover returned for failure of the assessee to substantiate the same by books\/purchase invoices the Assessing Officer determined the figure of turnover at Rs. 1,25,00,000\/- as against Rs. 98,52,500\/-just by a stroke of  pen. The Assessing Officer has nowhere applied his mind to the  figures of turnover for any other previous or subsequent years or to the graphs  of the  business  generally or by taking into consideration  the  increase  or decrease in the figures of sales of similarly situated traders. Though  the order refers to the figure of turnover for 1982-83 but does not say a  word about  the  basis whereon the figure for the year at hand was  arrived  at.\n<\/p>\n
What  was the nexus between the two figures and how it was arrived at?  The assessment is thus arbitrary and cannot be sustained.\n<\/p>\n
 16.  As  to the amount of interest charged under the Central Sales Tax  Act the  learned  counsel for the petitioner has invited the attention  of  the Court to the recent decision delivered by the Supreme Court of India in the case of India Carbon Ltd. Vs. State of Assam, (1997) 106 STC 460 SC, wherein  their Lordships have held that there being no substantive provision  in the  Central  Sales Tax Act requiring the payment of  interest  on  Central Sales  Tax, the Sales Tax Authorities of the State cannot, for the  purpose of  collecting and enforcing payment of Central Sales Tax, charge  interest thereon.\n<\/p>\n
 17.  For  the  foregoing  reasons, the petition is  allowed.  The  impugned orders  of assessment dated 28.3.88 (Annexure P-2) made under  Delhi  Sales Tax  Act,  1975 and the one made under Section 9 of the Central  Sales  Tax Act,  1956 for the period 1983-84 are both set aside. The orders passed  in revision and review sustaining the above said orders are also set aside. The Assessment Officer shall be at liberty to take up the assessment and  frame an order afresh consistently with the principles of law laid down  hereinabove and after affording the petitioner-assessee an opportunity of hearing. No order as to costs.<\/p>\n","protected":false},"excerpt":{"rendered":"
Delhi High Court Deepak Industries vs Salex Tax Officer, New Delhi & Ors. on 27 May, 1998 Equivalent citations: 1998 IVAD Delhi 753, 73 (1998) DLT 719, 1998 (46) DRJ 208 Author: R Lahoti Bench: R Lahoti, M Mudgal JUDGMENT R.C. Lahoti, J. 1. The petitioner is engaged in the business of building of bus […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_lmt_disableupdate":"","_lmt_disable":"","_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[14,8],"tags":[],"class_list":["post-7170","post","type-post","status-publish","format-standard","hentry","category-delhi-high-court","category-high-court"],"yoast_head":"\nDeepak Industries vs Salex Tax Officer, New Delhi & Ors. on 27 May, 1998 - Free Judgements of Supreme Court & High Court | Legal India<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.legalindia.com\/judgments\/deepak-industries-vs-salex-tax-officer-new-delhi-ors-on-27-may-1998\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Deepak Industries vs Salex Tax Officer, New Delhi & Ors. on 27 May, 1998 - 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