JUDGMENT The judgment of the Court was delivered by V. V. Kamat, J. - While deciding T.R.C. No. 201 of 1990 we have already specified the reason to decide this revision case separately, which we proceed to do hereafter. The assessment year in question is 1987-88. The declared turnover is Rs. 10,70,240 as considered by the assessee for the same reason of rejection of accounts, the assessing authority resorted to the best judgment approach and estimated the turnover in a similar manner, estimating the taxable turnover at Rs. 19,97,400. This was also based on the basis of the situation detected on inspection on March 17, 1988. 2. What was found as a result of this surprise inspection is available in the order of the first appellate authority and it is seen that the only item that was found in excess as a result of this inspection is a shortage of 5.800 grams of gold as against accounted sale of 3.350 grams. 3. This is specified in the order of the first appellate authority at the end to show that the assessing authority resorted to the estimate of turnover mainly in view of the stock variation - shortage of 5.800 grams of ornaments. It is further observed that this is against the total stock of 2,975.500 grams. It is necessary to emphasise that the first appellate authority has observed that the stock variation is very very small when compared to the total stock held at the time of inspection. In fact the statement of accounts submitted by the assessee have to be approached on the basis of an attitude of acceptance. This is even inspite of the power of the assessing authority to resort to best judgment assessment in a situation made available by peculiarity of facts and circumstances of each case. There is no dispute that the assessing authority has powers to resort to best judgment assessment and this power presumes existence of material justifying resort to such a power. If there are certain factors available on record justifying resort to the best judgment approach, there would not be any difficulty to resort to best judgment. There has to be material on record. This is an undisputed position and a settled one by a catena of decisions in regard thereto. 4. If there are certain factors available on record justifying resort to the best judgment approach, there would not be any difficulty to resort to best judgment. There has to be material on record. This is an undisputed position and a settled one by a catena of decisions in regard thereto. 4. However, the material on record shows that even the inspection revealed only a solitary aspect of shortage, this floats on the surface of the record as stated above. It may be that even a single item may justify resort to best judgment if that single item has sufficient magnitude to justifiably empower the assessing authority to resort to best judgment assessment. It is not necessary that a resort to best judgment assessment must be based on plurality of factors. 5. However, the factual matrix spell out hereinbefore shows that there is a single item of variation showing shortage of only 5.800 grams as against a total stock of 2,975.500 grams on the day of inspection. This situation is re-emphasized by the first appellate authority with a description that the stock variation is very very small when compared with the total stock held at the time of inspection. 6. In our judgment this situation leads us to hold that there was no justification whatsoever basically to reject the accounts submitted by the assessee when what is placed on record is a tiny quantity of 5.800 grams of ornaments as against the stock of 2,975.500 grams on that day. There is no other aspect requiring resort to best judgment assessment on the facts that are on record. In such a situation there is no justification to reject the accounts submitted by the assessee for the assessment year in question - 1987-88. 7. In fact even from the circulars of the department and the approach adopted by this Court in Kunhikannan v. State of Kerala 1993 KTR 598 the differences adopted at the time of inspection are worth appreciating. By the Circular No. 6 of 1990 dated June 5, 1990, the Board of Revenue recognised the difficulty occurring in gold trade having regard to the repeated weighments of small quantities as also weighment with stones. It is seen further that realising this problem directions are issued not to take any action against gold merchants if the excess stock found at the inspection was less than 2 per cent of the total stock. It is seen further that realising this problem directions are issued not to take any action against gold merchants if the excess stock found at the inspection was less than 2 per cent of the total stock. In fact this Court in Kunhikannan v. State of Kerala 1993 KTR 598 had an occasion to deal with the situation of rejection of accounts, where the excess was negligible however on facts when the court found that this was not a solitary situation but there were other aspects also, it has been observed even going to the extent that if this had been the only discrepancy showing negligible difference which also has to be appreciated in the light of the circulars of the department also. The result of the situation is obvious. Revision case stands allowed. Impugned orders both of all the authorities get quashed and set aside. The accounts submitted by the assessee stand accepted and the proceedings are remitted to the assessing authority for further steps according to law on the basis that the accounts submitted by the assessee are to be accepted and to be processed as such on the above basis. Petition allowed.