M. F. SALDANHA, J. ( 1 ) WE have heard the appellant's learned counsel at considerable length and his principal ground of attack in this appeal proceeds on the footing that the appellate authority set aside the assessment order on the ground that it did not proceed on the basis of cogent material but that the assessing authority had essentially gone on the basis of what he considered was a reasonable estimation. The learned counsel points out that in a case where there are no records, no evidence or no material or where there is a clear cut finding to the effect that the material or evidence that is on record does not inspire confidence the assessing authority may then be justified in adopting the standard of a reasonable estimation but he seriously finds fault with the procedure adopted in the present case and it is his submission that where regular accounts are maintained and where books of account are available these are a more reliable and correct basis for arriving at figures while passing assessment orders. To this extent, it is his contention that the appellate authority passed order in favour of the assessee whereby the appellate authority has directed a reassessment on a more realistic basis which is required to be upheld. Secondly, he has seriously found fault with the methodology adopted by the revisional authority who has exercised suo motu powers and has drawn conclusions which the learned counsel submitted are extremely far-fetched, arbitrary and bear no nexus to reality. He has demonstrated for instance, that on the basis of average formulate the authority even though he was of the view earlier that the figures require some upward revision, fixes the turnover at Rs, 60,000 per day without taking into account the other vital factors. Learned counsel demonstrated to us that it was pointed out that the major clientele of his hotel is from the educational institutions which are situated close by and that there is a significant drop in the turnover at times and that on this ground that the authority was in error in having taken a uniform average figure for every month of the year. The overall submission was that if the material before the revisional authority were to be even closely scrutinised by the court in the first instance there was no cause for interference with the appellate order which had only directed the reassessment and consequently even if the revisional authority were to re-scrutinise the original assessment order the gravity with which the figures have been revised upwards is totally unjustified. The contention raised therefore was that the revisional order should be set aside and that the reassessment as directed should be continued to be permitted. ( 2 ) LEARNED Government Advocate points out certain special features of this case, the first of them being that the assessee on his own volition has filed a revised return. He submits that where there is considerable down grading of the figures, it is not open to the assessee to contend that the earlier figures were on an approximation basis and the learned Government Advocate has drawn our attention to the fact that under the relevant provisions of law the monthly returns are expected to conform to the actual figures and not rough estimates. His submission is that where it is found on the assessee's own admission that there is a violent divergence between the monthly returns and the revised returns this itself totally destroys the aspect of credibility in the returns that are emanating from the assessee and he then re-enforces his argument by pointing out to us that this is the state of the assessee's records that it would not inspire any confidence in the documents and to then go back to the assessee's books of account and pass an assessment order in such circumstances would be futile. Further the learned counsel points out to us admittedly that this was a clear case in which there was an intention to suppress the vital aspects of the turnover from the department and he demonstrates that a whole lot of inputs which admittedly go into the production process in the hotel have been totally and completely avoided or suppressed and consequently his submission was that the department was therefore left with no option except to do a very careful analysis of the business, to estimate the figures and furthermore the officer has even visited the hotel, inspected what was going on and has come to a conclusion which is not at great variance from the figures which the assessee himself has disclosed. On the basis of these contentions, the learned Government Advocate submitted that even in a case where a reassessment has been ordered the revisional authority is not precluded from exercising revisional powers because the real question is as to whether the appellate authority was justified in interfering and if there is good ground to answer this question in the affirmative then it is well within the jurisdiction of the revisional authority to do a reassessment and arrive at a decision instead of mechanically sending the case back to the original authority. To this extent we do agree with the learned Government Advocate that the revisional authority is within its powers provided there is enough material and provided the process is correctly conducted, to reassess and arrive at a conclusion which has been done in the present case. ( 3 ) THE next question is as to whether on the material before us this is a case in which interference by the High Court in exercise of its appellate jurisdiction is warranted. Unless it is demonstrated to us that the conclusions arrived at by the revisional authority are inherently unsustainable, unless it is demonstrated that the revisional authority has by-passed well-settled provisions of the law or that the order is absolutely incorrect and perverse we really see no ground on which the appellate jurisdiction in a case like this can be invoked. Unless it is demonstrated to us that the conclusions arrived at by the revisional authority are inherently unsustainable, unless it is demonstrated that the revisional authority has by-passed well-settled provisions of the law or that the order is absolutely incorrect and perverse we really see no ground on which the appellate jurisdiction in a case like this can be invoked. We have addressed to ourselves the question as to whether assuming the submissions canvassed by the appellant's learned counsel are to be upheld there was any better method which the department could have adopted for the purpose of finding out a reasonable estimation of the turnover and having correctly examined the reasoning, the grounds given for the conclusions, the method in which the revisional authority has estimated various figures and arrived at an average basis we really do not see any valid ground on which these conclusions can be faulted. Having regard to this position, in our considered view, there is no scope left for the appellate court to exercise any jurisdiction. ( 4 ) THE appeal accordingly fails and stands dismissed no order as to costs.