SUBBA RAO, C.J.

This is a revision against the order of the Andhra Sales Tax Appellate Tribunal confirming that of the Deputy Commissioner of Commercial Taxes.

The petitioner is the proprietor of a non-vegetarian meals hotel called Sri Taj Mahal Hotel, Eluru. He was assessed for 1953-54 on a turnover of Rs. 27,000 on the best of judgment in the absence of a return from him. The Tribunal estimated the turnover at 4 times the cost of the mutton purchased. The learned counsel for the petitioner contended that the said multiple is arbitrary and is not supported by any reasonable basis. The Tribunal came to the conclusion, on the material placed before them, that, from 1st April, 1953, to 14th June, 1953, 2050 seers of mutton were purchased for Rs. 3072 working out an average roughly of 30 seers per day at Rs. 1-8-0 per seer. But, as there was no evidence of other purchases such as rice, vegetables, dhall, ghee, curd etc., which would be necessary to make a complete meal costing Rs. 1-4-0, the Tribunal estimated that four times the cost of the mutton purchased would represent the average sale proceeds per day, i.e., Rs. 180. On that footing, the net turnover for five months was