COMMISSIONER OF SALES-TAX, MADHYA PRADESH vs M/S. H.M. ESUFALL, H. M. ABDULALI, SIYAGANJ, INDORE

The Supreme Court held that the distinction between 'best judgment' assessment and assessment based on submitted accounts is crucial. Under Section 19(1) of the Madhya Pradesh General Sales Tax Act, 1958, and the Central Sales Tax Act, 1956, the Sales Tax Officer can reassess based on best judgment when the accounts are unreliable. The Court found that the Sales Tax Officer's estimation of turnover based on Rs. 31,171.28 from unaccounted sales was justified, as the assessee's false accounts indicated significant tax evasion, thus upholding the reassessment and penalty imposed by the authority.