M. F. SALDANHA, J.

( 1 ) WE have heard the appellant's learned counsel at considerable length and his principal ground of attack in this appeal proceeds on the footing that the appellate authority set aside the assessment order on the ground that it did not proceed on the basis of cogent material but that the assessing authority had essentially gone on the basis of what he considered was a reasonable estimation. The learned counsel points out that in a case where there are no records, no evidence or no material or where there is a clear cut finding to the effect that the material or evidence that is on record does not inspire confidence the assessing authority may then be justified in adopting the standard of a reasonable estimation but he seriously finds fault with the procedure adopted in the present case and it is his submission that where regular accounts are maintained and where books of account are available these are a more reliable and correct basis for arriving at figures while passing assessment orders. To this extent, it is his contention that the appellate authority passed order in favour of the assessee whereby the appellate authority has directed a reassessment on a

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