1 The petitioner is a private limited company carrying on the business of purchasing prawns, lobsters and frog legs, processing them in its factory at Cochin and selling them mostly to customers outside India and to a very limited extent to customers in India. Prawns and lobsters are taxable under the Kerala General Sales Tax Act, 1963 (hereinafter referred to as the Act) at the point of last purchase in the State. For the year 1964-65, the petitioner filed a return showing a net turnover of Rs. 16,83,180-61 in respect of purchase of these goods. The Sales Tax Officer rejected the petitioner's books of accounts and made a best judgment assessment. He fixed the net turnover by adding 40% of the returned turnover to make up for alleged suppression of purchases. The petitioner filed an appeal before the Appellate Assistant Commissioner without any success. It filed a second appeal before the Sales Tax Appellate Tribunal. The Tribunal agreed with the Subordinate authorities in rejecting the petitioner's accounts; but it held that the enhancement of the turnover by 40% was unreasonable, and limited the addition to Rs. 1,00,000/-. The petitioner has objected to the above order of the T

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