What is the difference between Assessment based on Best Judgement and Assessment based on books of accounts? Whether high court has power to substitute best judgement made by assessing authority?

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..... that t he distinction between a best judgment assessment and assessment based on the accounts submitted by an assessee must be borne in mind. Sometimes there may be innocent or trivial mistakes in the accounts maintained by the assessee. There may be even certain unintended or unimportant omissions in those accounts; but yet the accounts may be accepted as genuine and substantially correct. In .....

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..... of the assessee's accounts and those made on best judgment basis are totally different types of assessments. The assessing authority while making the best judgment assessment, no doubt, should arrive at its conclusion without any bias and on rational basis. That authority should not be vindictive or capricious. If the estimate made by the assessing authority is a bona fide estimate a .....

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