JUDGMENT Mohammed, J. 1. These two Tax Revision Gases filed by the Deputy Commissioner (Law), Board of Revenue (Taxes), Ernakulam relate to the assessment year 1982-83 and arise from a common order of the Sales Tax Appellate Tribunal, Kottayam in T. A. Nos. 281 and 292 of 1.990. T. A. No. 281 of 1990 was filed by the assessee whereas T. A. No. 292/90 was filed by the State of Kerala. 2. The assessee, M/s Prakkat Jewellers, dealing in gold and gold jewels is a registered dealer under the provisions of the Kerala General Sales Tax Act, 1963. In respect of the above year the assessee filed return in Form No. 8 declaring total and taxable turnover. In support of the said return accounts of the assessee were called for scrutiny. On verification of the accounts the officer has noticed various defects in the accounts. The main defect pointed out by the officer is that there were stock variations on inspection made by the Intelligence Officer, Kottayam on 25th February 1983. In view of these defects the officer formed an opinion that the accounts maintained by the assessee are incorrect and incomplete. Consequently a pre-assessment notice under S.17(3) of the Act was issued pointing out the defects and calling for explanation, if any. Since the objections filed by the assessee were found to be not acceptable the officer completed the assessment on best of judgment as proposed in the pre-assessment notice. The turnover was estimated on determining the average running stock and multiplied by five. As against the said assessment order passed by the officer the assessee filed an appeal, S. T. A. No. 519 of 1990, before the Deputy Commissioner (Appeals). The Deputy Commissioner upheld the rejection of accounts and estimation of the turnover on best of judgment. However, as far as estimate is concerned, the Deputy Commissioner reduced the addition by fixing the turnover on the basis of 2 1/2 times of the average funning stock. As against the said order both the assessee and the Department filed appeals before the Sales Tax Appellate Tribunal. The Appellate Tribunal by its order dated 29th November 1990 upheld the rejection of accounts and the estimation of the turnover on best of judgment. As far as the estimate is concerned, the Appellate Tribunal reduced the value of the average running stock to Rs. The Appellate Tribunal by its order dated 29th November 1990 upheld the rejection of accounts and the estimation of the turnover on best of judgment. As far as the estimate is concerned, the Appellate Tribunal reduced the value of the average running stock to Rs. 34,55,958 and taxable turnover was fixed two times of the said average running stock. The Department being aggrieved by the said order has filed these Tax Revision Cases. 3. Heard learned Government Pleader for the petitioner and the counsel for the assessee. 4. The Tribunal after considering the materials on record agreed with the conclusions of the authorities below that the accounts maintained by the assessee were incorrect and improper. It also agreed to the conclusion that the circumstances available in this case warrant an assessment under best of judgment. The Tribunal particularly observed that it agreed with the aforesaid conclusions of the . authorities below in view of the results gathered from the three inspections to the business premises of the assessee made by the Intelligence Department of the Government. In view of the aforesaid circumstances, we concur with the findings of the authorities below in respect of the correctness and completeness of the accounts and initiation of assessment under best of judgment. 5. The next question remains to be considered is whether the estimate fixed by the Tribunal is justified in the facts and circumstances of this case? While dealing with this question we must recall that the Appellate Tribunal is the highest fact finding authority under the provisions of the Act. The findings based on appreciation of evidence entered by the Tribunal should be given due weight while dealing with the correctness of its conclusions in exercise of power conferred on this court under S.41 of the Act. In the absence of correct and complete accounts the assessing authority fixed the turnover on the basis of the value of stock in trade. Usually the average running stock value is arrived at by using a simple formula, namely, opening stock+closing stock/2. Applying this method, value of the average running stock as per the accounts of the assessee was determined. However, in order to fix the taxable turnover the average running stock will have to be multiplied. Ordinarily six times of the average running stock is adopted for fixing the taxable turnover. But this is not an inflexible rule or formula. Applying this method, value of the average running stock as per the accounts of the assessee was determined. However, in order to fix the taxable turnover the average running stock will have to be multiplied. Ordinarily six times of the average running stock is adopted for fixing the taxable turnover. But this is not an inflexible rule or formula. It depends on the nature of the trade, system of accounting, stock value, nature of defects etc. The case in hand is one relates to business in gold and gold jewels. The stock in trade of gold has its own specialities. It cannot be compared with the stock in ordinary trade or business. Probably in view of that reason while fixing the taxable turnover in the case of a gold dealer a different outlook has been made by the courts. A Division Bench of this court in the case of the same assessee relating to the assessment year 1985-1986, while disposing of the similar Tax Revision Case by the State, had agreed with the Tribunal in adopting 1.5 times of the average running stock for fixing the taxable turnover. (See T. R. C. No. 96 of 1994 dated 3rd November 1994). 6. Learned counsel for the assessee brought to our notice yet another decision of a Division Bench of this court in T. R. C. Nos. 52 and 54 of 1987. That was also a case of dealer in gold and silver. The Tribunal in that case directed the assessing authority to determine the turnover at two times of the average running stock in the case of gold and silver. There the Division Bench observed: "We are of the view that the quantum of estimate is also ordinarily a question of fact and no ground was made out to interfere with the said finding". Therefore, the Division Bench did not interfere with the order of the Tribunal in that case. In view of the above stark realities we cannot agree to the suggestion of the State to adopt the usual method of fixing the taxable turnover at five or six times of the average running stock in this case. The Tribunal, as observed earlier being the highest fact finding authority, fixed the turnover at two times of the average running stock. We do not propose to upset the aforesaid conclusion in view of the decisions of this court cited supra. The Tribunal, as observed earlier being the highest fact finding authority, fixed the turnover at two times of the average running stock. We do not propose to upset the aforesaid conclusion in view of the decisions of this court cited supra. Further, when the Tribunal has fixed the method of determining the turnover, ordinarily this court will not interfere. 7. In this context we must observe that the Tribunal has given its own reasons for fixing the aforesaid formula. On closer scrutiny of the defects it observed that those defects cannot be added together as separate and independent defects and the weight of the cumulative effect cannot be thrown over the back of the assessee in the form of an exorbitant addition. The Tribunal also considered another important aspect, namely, the seizure of the gold by the Central Excise authorities on 21st August 1982 which seizure established only the unaccounted stock holding and not unaccounted sales. The gold seized on 21st August 1982 was ordered to be redeemed by the Collector, Central Excise only on 12th October 1986. The quantity of the gold seized was not within the possession of the assessee during the assessment year and hence no unaccounted sales could be estimated with reference to that quantity of gold seized by the Central Excise authorities as the gold was redeemed only after four years. Therefore, in view of the aforesaid irregularities the Tribunal estimated the sales turnover on the basis of the average running stock multiplied by two. It is unnecessary for us to elaborate on this aspect because the Tribunal after considering the entire materials, came to the conclusion that two times of the average running stock would be reasonable in the facts of this case. We do not propose to disturb the said conclusion. We accordingly confirm the order of the Tribunal. The T. R. Cs. are accordingly dismissed.