JUDGMENT The judgment of the Court was delivered by V. V. KAMAT, J. - There were two appeals before the Kerala Sales Tax Appellate Tribunal under the Kerala general sales tax assessment and the other under Central sales tax assessment. The relevant year is 1985-86. The present revision case relates to Kerala general sales tax assessment, the assessment in regard to Central sales tax has not been challenged and therefore has become final. 2. The petitioner is a dealer in machinery tools, electrical items, wooden furniture and in regard thereto the assessing authority made addition of 20 per cent to the conceded taxable turnover and also estimated 70 per cent addition to the sales tax turnover of 70 per cent as the corresponding purchase turnover taxable under section 5A. 3. For the year in question annual return declaring total and taxable turnover of Rs. 22,95,907.86 was filed. The books of accounts of the assessees were called for and examined by the trial authority. The books were found not acceptable because (1) there was difference between turnover as per accounts and return and the difference was not properly explained; (2) there was fall in the turnover when compared to the previous year and there was no satisfactory explanation in regard thereto; (3) no manufacturing account was found to have been maintained and other reasons enumerated in the order of the trial authority. 4. This led to the issuance of a notice under section 17(3) of the Kerala General Sales Tax Act and taxable turnover of Rs. 28,21,973.30 and Rs, 23,07,080, respectively. Objections were filed and by the order the trial authority considered the situation as far as the present proceedings are concerned. The reason is regarding non-maintenance of the manufacturing account and the explanation in regard thereto that it is not practicable to maintain manufacturing accounts. This explanation was not accepted. The authority held that the reasons for low turnover and difference between turnover as per the accounts and return as well as absence of stock inventory and explanation in regard thereto could not be considered at all as convincing. 5. There was an appeal to the first appellate authority - Additional Deputy Commissioner (Appeals) II, Ernakulam. The appellate authority considered the question with regard to the contentions raised before it and perused the records. 6. 5. There was an appeal to the first appellate authority - Additional Deputy Commissioner (Appeals) II, Ernakulam. The appellate authority considered the question with regard to the contentions raised before it and perused the records. 6. The appellate authority has also concurred with the trial authority that no manufacturing accounts maintained and all the purchases were not supported by bills. It is emphasised that no bills were produced for local purchases as well as for the purchase of raw materials in the furniture section. 7. Considering the nature and volume of business, the appellate authority found that additions were very reasonable and in the absence of additional evidence, the appellate authority considered that it is not possible to interfere with the addition proposed by notice under section 17(3) of the Act. 8. The matter was taken up before the Sales Tax Appellate Tribunal. Reading the judgment of the Tribunal it is found that rejection of the return and accounts for the reasons in regard thereto was justifiable. The contention that low turnover and fall in turnover could not be a reason to reject the accounts, has not been accepted. It was also emphasised before the Tribunal that the manufacturing activity is only in respect of furniture and therefore the Tribunal found that defect of non-maintenance of manufacturing account would be as it would affect the turnover of furniture alone that being the only activity. The Tribunal was also careful in considering the daily stock register and stores register and found that manufacturing account in respect of furniture is not there, which was urged before the Tribunal by way of a contention. The contention is that the manufacturing account is relevant only in respect of furniture and as there was no inspection there could be no consideration of suppression. The Tribunal found that the manufacturing account is relevant and more so in respect of furniture. 9. Even then the Tribunal modified the addition from 70 per cent to 50 per cent of the admitted taxable turnover under furniture. 10. Learned counsel has preferred revision before this Court with regard to the following three questions : "1. Whether, the Tribunal is justified in making addition of 50 per cent to the conceded turnover under furniture and further addition of 50 per cent of the said addition under section 5A after finding that there are daily stock register and stores register ? 2. Whether, the Tribunal is justified in making addition of 50 per cent to the conceded turnover under furniture and further addition of 50 per cent of the said addition under section 5A after finding that there are daily stock register and stores register ? 2. In the absence of any other substantial defects in the accounts whether the Tribunal is justified in rejecting the books of accounts kept in the usual course of the business on the ground of absence of manufacturing accounts ? 3. In the manufacture of furniture the materials left over during the production of various items may or may not find use in further production. In such cases the absences of manufacturing accounts in the strict sense in rule 32(15) can be taken as a ground for rejection of the books of accounts and estimation of turnover ?" With regard to question No. 1 it would be seen that it is a question relating to the exercise of discretion relating to the deduction of percentage. It is not possible to exercise powers under section 41 of the Kerala General Sales Tax Act in regard thereto. 11. With regard to question No. 2, it would have to be appreciated that the only activity of the assessee was furniture as has been found in regard to which there is no account and the explanation in regard thereto that it is not practicable has been rejected. It must be emphasised that beyond slating that it is not practicable, there is no explanation whatsoever. 12. With regard to question No. 3 regarding the provisions of rule 32(15) of the Kerala General Sales Tax Rules, learned counsel relied on the earlier decision of this Court (T.R.C. 1 of 1970 dated March 18, 1971). On going through the judgment it would appear at once that this Court has already held that under rule 32(15) of the Sales Tax Rules every manufacturer of goods has to maintain daily production accounts showing quantitative details of the various raw materials used for the manufacture and the quantitative details of the goods so manufactured and the assessee has not maintained any accounts of this nature. Learned counsel submitted that the rule should not be considered as mandatory. Learned counsel submitted that the rule should not be considered as mandatory. Going through the contents of the rule when the rule makes it obligatory on the assessee to maintain accounts with regard to the production giving necessary quantitative details of the various raw materials used for the manufacture as well as the quantitative details of the goods so manufactured it is difficult to accept the submission more so in view of the fact that earlier also in the judgment placed before us the court proceeded to consider the explanation in regard to non-maintenance and passed orders in regard thereto. Independently also it is not possible to accept the submission that the rules are directory in nature when the rule makes provision for so many details in regard thereto. 13. Consistent view of the three authorities is that manufacturing account in regard to the furniture production has not been maintained at all not to speak of any details in regard thereto. In view of this position, the manufacture of furniture being the only item much of the amount liable to sales tax has not appeared before the authority and the authorities could not be considered to be in error in any manner in exercising powers under section 17 of the Kerala General Sales Tax Act proposing estimated total and taxable turnover and acting upon it in consequence. The factual material shows that powers under section 41 of the Kerala General Sales Tax Act cannot be exercised. Revision case stands dismissed at the stage of admission. Petition dismissed.