ORDER H. S. KAMATH, PRESIDENT. - The applicant has his head officer at Yeotmal and branch offices at eight other places in the State. For the period to which the assessment relates, namely, 1st June, 1947, to 14th November, 1947, he was able to produce his books of accounts for all shops, except those at Akola and Yeotmal. The books pertaining to these shops were burnt some time before he was asked to produce them. Accordingly the Assistant Commissioner proceeded to make his assessment in respect of these shops to the best of his judgment under Section 11(4) of the Act. The applicant questions the validity of that assessment. 2. Practically the only reasons urged are in terms of arithmetic. To understand them, I have prepared the following statement :- In respect of In respect of all shops. shops at Akola and Malkapur only Gross turnover returned by 39.90 lacs. 10.29 lacs. assessee. Gross turnover determined by Assessing Officer ... 41.43 " 10.93 " ----- ------ Total enhancement : ... 1.53 " .64 " Percentage enhancement ... 3.8 6.2 (Figures have been given above correct to the nearest thousand rupees). 3. The applicant's grievance is that in respect of the Akola and Malkapur shops, a higher percentage of enhancement has been adopted by the Assessing Officer. He has no grievance about the general percentage of enhancement and his plea is that something like the same figure would have been appropriate for the Akola and Malkapur shops also, or that at least some convincing reasons should have been given for adopting a higher percentage. In opposing this point of view, the learned counsel for the State has relied on Commissioner of Income-tax, United and Central Provinces v. Badridas Ramrai Shop, Akola ([1937] 5 I.T.R. 170; I.L.R. 1937 Nag. 191). The case arose out of an analogous provision of the Income-tax Act under which the Income-tax Officer is required to make his assessment according to the best of his judgment and the principles laid down by their Lordships of the Privy Council must, it is urged, apply here, too :- "........The Officer is to make an assessment to the best of his judgment against a person who is in default as regards supplying information. He must not act dishonestly or vindictively or capriciously because he must exercise judgment in the matter. He must not act dishonestly or vindictively or capriciously because he must exercise judgment in the matter. He must make what he honestly believes to be a fair estimate of the proper figure of assessment.................and though there must necessarily be guess-work in the matter, it must be honest guees-work. In that sense too the assessment must be to some extent arbitrary." 4. The appropriateness of these principles in respect of assessments made under Section 11(4) of our Sales Tax Act has not been seriously questioned by the applicant's learned counsel. All that he urges, however, is that to make the proceedings an honest effort at assessment, there must be some reasons given for the assessment made. In broad terms, this proposition can be accepted, though in revisional proceedings under the Act any minute scrutiny of the reasons given will be out of place. In this particular case it is not correct to say that no reasons have been given. "I have estimated these figures", says the Assessing Officer in respect of the figures of gross turnover determined by him for the Akola and Malkapur shops, "after giving due consideration to the misclassification made by the assessee in the accounts of other branches." In the circumstances in which he found himself by the inability of the assessee to produce his account books, it is difficult to see how he could have given his reasons at any great length. It is, of course, possible that another officer may have viewed the case from a different angle; but that possibility by itself does not vitiate the proceedings of the officer who actually handled the case. Moreover, the contention that a particular figure of percentage enhancement was appropriate and that another figure was not cannot be said to raise any substantial question of law, which is the only ground on which revision can be considered. 5. For the reasons given above, I see no case for interference with the findings and decisions of the departmental officers and I, therefore, reject this application for revision. Application rejected.