Best assessment judgment The distinction between a ‘best judgment’ assessment and assessment based on the accounts submitted by an assessee must be borne in mind. Sometime there may be innocent or trivial mistakes in the accounts maintained by the assessee. There may be even certain unintended or unimportant omissions in those accounts ; but yet the accounts may be accepted as genuine and substantially correct. In such cases, the assessments are made on the basis of the accounts maintained even though the assessing officer may add back to the accounts price of items that might have been omitted to be included in the accounts. In such a case, the assessment made is not a ‘best-judgment’ assessment. It is primarily made on the basis of the accounts maintained by the assessee. But when the assessing officer comes to the conclusion that no reliance can be placed on the accounts maintained by the assessee, he proceeds to assess the assessee on the basis of his ‘best-judgment’. In doing so, he may take such assistance as the assessee’s accounts may afford, he may also rely on other information gathered by him as well as on the surrounding circumstances of the case. The assessments made on the basis of assessee’s accounts and those made on ‘best-judgment’ basis are totally different types of assessment. (Commr. of Sales Tax v. H.M. Esupali, (1973) 2 SCC 137 (141)