VEERASWAMI, J.

The petitioner is a private limited liability company and seeks to have an order of the Joint Commercial Tax Officer, Harbour Division II, quashed. The assessment to sales tax relates to the assessment year 1965-66. The return for the year was due to be filed on or before May 1, 1965, but it was actually filed only on December 31, 1966. In the meantime, the Joint Commercial Tax Officer started proceedings proposing by his notice dated December 28, 1966, to determine the taxable turnover by best judgment at a certain figure and to levy tax at different rates on different items of turnover specified in the notice. It appears that by then the assessing officer had called upon the petitioner to produce accounts and for the purpose granted at its request several adjournments, but finally, he declined to give time beyond December 15, 1966. The explanation for filing the return belatedly was that the petitioner had to receive figures from various places of business and compile the same to fill in the return. The Joint Commercial Tax Officer made an assessment by an order dated January 4, 1967, by applying his best judgment. He though that the return filed before