JUDGMENT OM PRAKASH, C.J. – Heard counsel for the parties. 2. Revision-petitioner is engaged in the business of manufacture and sale of gold ornaments. The business premises of the revision-petitioner was inspected on May 20, 1988. The relevant assessment year is 1988-89. On inspection, stock variations were noticed. New gold ornaments were found in excess by 3.425 grams. Old gold ornaments were short by 1.600 grams. As per the vouchers recovered by the inspecting team, it was found that the dealer failed to account for 107.300 grams of gold, said to have been given to a goldsmith for melting. It is said that the dealer did not account for the sales of gold ornaments to the tune of Rs. 10,590. Later, these offences came to be compounded on payment of compounding fee. 3. On the above defects in the book-keeping of the dealer, the assessing officer concluded as follows : ".......... I am fully convinced that the assessee have resorted to large scale suppression both in sales and purchases during the year." 4. The assessing officer, therefore, estimated the sales turnover for the assessment year 1988-89 at three times of the average stock (3 x 10,05,370, i.e. at Rs. 30,16,110). The dealer appealed to the appellate authority, but failed. Thereafter, the dispute was carried before the Sales Tax Appellate Tribunal, which too dismissed the appeal. 5. So far as the defects point out in the book-keeping are concerned, we are of the view that the book version has got to be rejected and to that extent we see no error in the impugned orders of the authorities below. 6. The question for consideration is whether on the basis of the discrepancies found, it could be said that the dealer had resorted to large scale suppression both in sales and purchases during the year. No material has been pointed out on the record by the authorities below to support such conclusion, arrived at by the assessing authority. It is well-settled that if there is discrepancy, the book version can be rejected and the best judgment assessment can be made. But the law is that the best judgment assessment should be fully supported by the materials available on records. After rejecting the book version, the assessing authority is not free to make the best judgment assessment to any extent. But the law is that the best judgment assessment should be fully supported by the materials available on records. After rejecting the book version, the assessing authority is not free to make the best judgment assessment to any extent. The best judgment assessment should be reasonable, consistent to the materials, available on the record and not arbitrary. Though the assessing authority found that the dealer resorted to large scale suppression both in sales and purchases, but there is no supportive material to this effect. The Appellate Tribunal also has not pointed out any material supporting the conclusion, arrived at by the assessing officer. Rather, the Appellate Tribunal found that "Even though the value of the stock variations is very nominal as canvassed by the learned counsel, the offences established in this case are substantial and serious in nature." We called upon the Government Pleader to demonstrate the seriousness of the discrepancies, found in the case. He has not been able to point out any instance in support of the fact that the discrepancies found were substantial or serious in nature. 7. Looking to the facts of the case, we are of the view that there is nothing on the records to uphold the addition, made by the assessing officer. The assessment order ultimately upheld by the Sales Tax Appellate Tribunal, on the face of it appears to be arbitrary and on a much higher side. In the result, the T.R.C. succeeds and is allowed; the impugned order of the Appellate Tribunal is set aside and the case is remanded to the Appellate Tribunal with the direction that the appeal will be decided by the Tribunal afresh taking into consideration the extent of the discrepancies, pointed out on the records. Until a decision by the Tribunal as aforesaid, no tax will be realised from the revision petitioner pursuant to the order of the assessing officer. The revision petitioner shall produce a certified copy of this judgment to the Sales Tax Appellate Tribunal within two weeks from today, failing which the stay order will stand vacated. A certified copy of the judgment will be supplied to the revision petitioner within two days on usual payment. Order on CMP No. 481 of 1997 in TRC No. 13 of 1997 dismissed. Petition allowed.