JUDGMENT BAKTHAVATSALAM, J. - The appellant before us, who is a dealer in pulses and grams, was assessed for the assessment year 1977-78 on a total and taxable turnover of Rs. 15,51,366.75 and Rs. 13,23,630.79 by the assessing officer. The assessing officer noticed certain defects and so rejected the accounts as incorrect and incomplete and therefore estimated the turnover by adding 7 1/2 per cent towards possible omission and also levied a penalty of Rs. 56. He arrived at such a conclusion on three grounds : (1) the gross profit works out to 5.3 per cent only as against 10 per cent as per the survey report, (2) the outturn under various categories is very low as compared with the survey report and (3) discrepancies noticed during inspection in the stock in respect of black gram dhall and dust to the extent of 214 bags and 10 bags respectively. On appeal, the Appellate Assistant Commissioner took note of the fact that during the inspection on August 11, 1977 there was no irregularity in the stock whereas on the subsequent inspection on August 20, 1977 the difference in stock was noticed and a difference having been established it called for an estimation. But regarding quantum the appellate authority did not accept the 7 1/2 per cent addition for probable omission, but considering the other items added an ad hoc amount of Rs. 3,000, which according to him will meet the ends of justice. However the penalty aspect of the order has been affirmed by the appellate authority. On a suo motu revision under section 34 of the Tamil Nadu General Sales Tax Act, a notice was issued to the appellant stating that the main defect was the shortage of 2 1/2 bags of black gram dhall and 10 bags of dust detected during the second inspection on August 20, 1977, which calls for a higher estimation. To repeat the words of the Joint Commissioner in his order : "A dealer having an admitted taxable turnover of Rs. 12,31,294 would not suppress a mere Rs. 3,000. The estimate is not realistic." So on the ground that the addition made by the assessing officer is justified having reasonable nexus to the facts and after having received the objections from the appellant and also hearing the learned counsel for the appellant, restored the order of the assessing authority. 12,31,294 would not suppress a mere Rs. 3,000. The estimate is not realistic." So on the ground that the addition made by the assessing officer is justified having reasonable nexus to the facts and after having received the objections from the appellant and also hearing the learned counsel for the appellant, restored the order of the assessing authority. In doing so, the revisional authority has go confused himself in-between section 16 and section 34 of the Tamil Nadu General Sales Tax Act. After explaining the powers under various sections, the revisional authority has come to the conclusion that the appellate authority has not used its discretion properly and that the entries are not made then and there in the account books and they do not reflect the correct day-to-day transaction leading to the suppression of actual turnover. Apart from this reasoning, we do not find any material in the order passed by the revisional authority. Mr. Chandran, learned counsel for the assessee contends that the well-considered order of the appellate authority was revised by the Joint Commissioner exercising his power under section 34 of the Act in a casual manner and in a light hearted fashion without any basis. According to the learned counsel the alleged excess stock in dhall and dust related to the commodities of production and that has been considered by the Appellate Assistant Commissioner. Per contra, learned Additional Government Pleader tried in vain to defend the orders of the revisional authority. When it is pointed to the Additional Government Pleader that the only reason on which notice has been given to the appellant is about the difference in stock, the learned Additional Government Pleader sought to contend that it was not for that sole reason, and apparently the counsel has no answer for the counsel is not in a position to improve the case beyond what is contained in the records. Considering the rival arguments, we are of the view that this is a fit case where this Court has necessarily to interfere with the order passed by the revisional authority under section 34 of the Act. The Joint Commissioner seems to have felt that if it is a big dealer the addition should be more and if it is a small dealer there cannot be any addition at all. The Joint Commissioner seems to have felt that if it is a big dealer the addition should be more and if it is a small dealer there cannot be any addition at all. This reasoning alone is sufficients to interfere with the order of the Joint Commissioner, which is challenged in this appeal. Further, the Joint Commissioner being a higher authority in the hierarchy of officers has got the powers to revise the orders if there is some patent discrepancy and difference and he should not interfere with the orders of the lower authorities when there is no ground at all to do so. We do not see any reason how the Joint Commissioner differed from the well-considered order of the first appellate authority who felt that the addition of 7 1/2 per cent for probable omission is not called for and an ad hoc addition of Rs. 3,000 would be sufficient. It has been held by a Division Bench of this Court in Avon Plastics v. State of Tamil Nadu [1982] 49 STC 268 that unless the discretion by the appellate authority has been wrongly exercised, it would not be proper for the Board of Revenue to interfere with the order of the Appellate Assistant Commissioner under section 34 of the Act. In Kuppuswamy & Sons v. State of Tamil Nadu [1982] 51 STC 143 a Division Bench of this Court has held that the Board of Revenue in arriving at a turnover should not act mechanically but should act judicially while exercising its power of revision. So the function of the Board of Revenue is to find out whether the order of the Appellate Assistant Commissioner is reasonable and not to interfere with the order arbitrarily. In this view of the matter, the order under appeal is set aside and the order of the Appellate Assistant Commissioner is restored. The appeal stands allowed. No costs. Appeal allowed.