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“best judgment assessment”

Assessment ProceduresSection 144Section 1441,400 judgments

The decision most relied on for best judgment assessment is Kachwala Gems v. JCIT (288 ITR 10), cited in 332 judgments on BharatTax.

Leading authorities on best judgment assessment

Kachwala Gems v. JCIT
288 ITR 10 · 2007 · Supreme Court
332
citing judgments

In a best judgment assessment, some guesswork is inherent, but the estimate must be fair and not arbitrary. Books of account can be rejected under Section 145(3) if the assessee fails to substantiate entries or prove the genuineness of transactions, leading to estimation of income.

Commissioner of Sales Tax v. H.M. Esufali H.M. Abdulali
90 ITR 271 · 1973 · Supreme Court
232
citing judgments

The Supreme Court established principles for best judgment assessments, stating that some guesswork is inevitable but the assessment must be bona fide, rational, and free from bias or capriciousness. An appellate authority cannot substitute its judgment for that of the Assessing Officer unless the AO's assessment is shown to be biased, irrational, vindictive, or capricious, especially when the assessee fails to provide proper accounts or counter-evidence.

CIT v. Gurubachhan Singh J. Juneja
302 ITR 63 · 2008 · High Court
147
citing judgments

When unaccounted receipts or suppressed sales are detected and books of account are rejected under Section 145(3), additions to income must be restricted to the profit element embedded in such transactions, not the entire transaction value. This profit element is to be estimated by considering the assessee's regular profit ratio as per books of account.

Man Mohan Sadani v. CIT
304 ITR 52 · 2008 · High Court
132
citing judgments

When assessing income from undisclosed or unrecorded sales, the entire sale proceeds cannot be added to the assessee's income; instead, only the net profit embedded in such unaccounted sales, determined by applying the assessee's net profit rate, should be taxed.

Brij Bhushan Lal Paraduman Kumar v. CIT
115 ITR 524 · 1978 · Supreme Court
113
citing judgments

The Supreme Court holds that an Assessing Officer, when making a best judgment assessment or estimating income, must act fairly, honestly, and rationally, basing the estimation on available material and avoiding arbitrary or capricious decisions. Adherence to natural justice principles is crucial during assessment proceedings.

CIT v. Laxminarain Badridas
5 ITR 170 · 1937 · Supreme Court
79
citing judgments

An income tax officer making a best judgment assessment must act honestly, not dishonestly, vindictively, or capriciously. They must make a fair estimate of the assessment, considering local knowledge, repute, and previous assessments.

State of Kerala v. C. Velukutty
60 ITR 239 · 1966 · Supreme Court
78
citing judgments

A best judgment assessment must be based on wisdom, truth, and legal principles, not arbitrary caprice. While it involves estimation and guesswork, this must have a reasonable nexus to available material and the case's circumstances.

Shankar Khandasari Sugar Mills v. CIT
193 ITR 669 · 1992 · High Court
64
citing judgments

Best judgment assessments under Section 144 must be a fair and rational estimation of income by the Assessing Officer, not capricious or arbitrary. Appellate authorities should accept clarificatory evidence to test the fairness of such assessments, even if produced for the first time.

Judgments citing best judgment assessment

Vatsalabai Karbhari Deore, Nashik vs. Assistant Commissioner of Income Tax, Circle - 1, Nashik

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2056/PUN/2025[2014 - 15]Status: DisposedITAT Pune27 Oct 2025

Bench: Dr.Manish Borad & Ms. Astha Chandra

For Appellant: Shri Sanket JoshiFor Respondent: Shri Bharat Andhale
Section 143(2)Section 144Section 250

file of ld. Jurisdictional Assessing Officer for denovo adjudication on the ground that assessee failed to make any compliance before ld. AO and best judgment assessment has been framed u/s.144 of the Act. He also submitted that against the gross profit rate of 7.35% declared by the assessee, ld.CIT ... carried out the assessment proceedings. However, in absence of any response from the assessee and non-submission of any details, ld. AO passed best judgment assessment making two additions firstly by disallowing interest expenses at Rs.57,96,647/- and secondly estimating the net profit @8% on the total turnover after

Rajendra Annasaheb Masute HUF, Kolhapur vs. ITO, Ward-1(1), Kolhapur

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 1191/PUN/2025[2021-22]Status: DisposedITAT Pune27 Oct 2025AY 2021-22

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1191/Pun/2025 Assessment Year : 2021-22

For Appellant: NoneFor Respondent: Shri Bharat Andhale
Section 144Section 69

that the assessment year in the case of assessee HUF for A.Y. 2021-22 has been framed u/s.144 r.w.s.144B of the Act as Best Judgment assessment and addition of Rs.54,91,038/- has been made against the Nil income declared in the income-tax return filed on 31.12.2021. Assessee

Krish Wines, Jalgaon vs. ACIT Circle 1, Jalgaon

ITA 2098/PUN/2024[2017-18]Status: DisposedITAT Pune27 Oct 2025AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandra

Section 142(1)Section 143(2)Section 145Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND MS. ASTHA

Sri Vinayaga Builders and Homes Pvt. Ltd., Chennai vs. ITO, Corporate Ward-6(3), Chennai

In the result, appeals filed by the assessee are allowed for statistical

ITA 2104/CHNY/2025[2017-18]Status: DisposedITAT Chennai24 Oct 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

Section 144Section 148Section 69A

which also is noted to be passed u/s.144 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act‘) [best judgment assessment] for AY 2016-17 as well as for AY 2017-18. According to the Ld.AR, a perusal of the assessment order would show that

Sri Vinayaga Builders and Homes Pvt. Ltd., Chennai vs. ITO, Coporate Ward-6(3), Chennai

In the result, appeals filed by the assessee are allowed for statistical

ITA 2103/CHNY/2025[2016-17]Status: DisposedITAT Chennai24 Oct 2025AY 2016-17

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

Section 144Section 148Section 69A

which also is noted to be passed u/s.144 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act‘) [best judgment assessment] for AY 2016-17 as well as for AY 2017-18. According to the Ld.AR, a perusal of the assessment order would show that

Sarveswaran Deepa, Kanchipuram vs. The Income Tax Officer, Non Corp Ward 22(6), Tambaram

The appeal of the assessee is partly allowed

ITA 1973/CHNY/2025[2015-16]Status: DisposedITAT Chennai23 Oct 2025AY 2015-16

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri. R. S. Lakshmi Narayana, Advocate
Section 142(1)Section 147Section 148Section 271(1)(b)Section 274

notice u/s.142(1) of the Act, the appropriate remedy available to the AO is to proceed u/s.144 of the Act to frame a best judgment assessment, and not to repeatedly levy penalty u/s.271(1)(b) of the Act for the same default. 11. In view of the foregoing

Kiran Reddy Muddasani, Hyderabad vs. Income Tax Officer, Ward-9(3), Hyderabad

In the result, ITA.No.1157/Hyd

ITA 1158/HYD/2025[2012-13]Status: DisposedITAT Hyderabad17 Oct 2025AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1157 & 1158/Hyd./2025 िनधा"रण वष"/Assessment Year 2012-2013 Kiran Reddy Muddasani, The Income Tax Officer, Hyderabad – 500 035. Ward-9(3), Vs. Telangana. Hyderabad – 500 004. Pan Bftpm6705H Telangana. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Sri P. Vinod, Advocate राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 15.10.2025 घोषणा की तारीख/Pronouncement: 17.10.2025 आदेश/Order Per Vijay Pal Rao: These Two Appeals Ita Nos.1157 & 1158/Hyd./2025 By The Assessee Are Directed Against The Two Separate Orders Of The Learned Cit(A)-National Faceless Appeal Centre [In Short “Nfac”], Delhi, Both Dated 26.05.2025 Arising From Assessment Order Passed U/Sec.147 R.W.S.144 Of The Income

For Appellant: Sri P. Vinod, AdvocateFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 147Section 148Section 271(1)(c)

behalf of the assessee to the notice issued 8 ITA.No.1157 & 1158/Hyd./2025 by the Assessing Officer, therefore, the Assessing Officer passed the best Judgment assessment order u/sec.144 r.w.s.147 of the Income Tax Act, 1961, whereby the deposit in the bank account was assessed as unexplained money u/sec.69A ... appellant company u/sec.148A of the Act, but, the assessee neither responded nor filed any details. Therefore, the Assessing Officer has passed the best judgment assessment order u/sec.144 r.w.s.143(3) of the Income Tax Act, 1961 for both the assessment years and made additions towards transactions reported by the DGFT. Since

Kiran Reddy Muddasani, Hyderabad vs. Income Tax Officer, Ward-9(3), Hyderabad

In the result, ITA.No.1157/Hyd

ITA 1157/HYD/2025[2012-13]Status: DisposedITAT Hyderabad17 Oct 2025AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1157 & 1158/Hyd./2025 िनधा"रण वष"/Assessment Year 2012-2013 Kiran Reddy Muddasani, The Income Tax Officer, Hyderabad – 500 035. Ward-9(3), Vs. Telangana. Hyderabad – 500 004. Pan Bftpm6705H Telangana. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Sri P. Vinod, Advocate राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 15.10.2025 घोषणा की तारीख/Pronouncement: 17.10.2025 आदेश/Order Per Vijay Pal Rao: These Two Appeals Ita Nos.1157 & 1158/Hyd./2025 By The Assessee Are Directed Against The Two Separate Orders Of The Learned Cit(A)-National Faceless Appeal Centre [In Short “Nfac”], Delhi, Both Dated 26.05.2025 Arising From Assessment Order Passed U/Sec.147 R.W.S.144 Of The Income

For Appellant: Sri P. Vinod, AdvocateFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 147Section 148Section 271(1)(c)

behalf of the assessee to the notice issued 8 ITA.No.1157 & 1158/Hyd./2025 by the Assessing Officer, therefore, the Assessing Officer passed the best Judgment assessment order u/sec.144 r.w.s.147 of the Income Tax Act, 1961, whereby the deposit in the bank account was assessed as unexplained money u/sec.69A ... appellant company u/sec.148A of the Act, but, the assessee neither responded nor filed any details. Therefore, the Assessing Officer has passed the best judgment assessment order u/sec.144 r.w.s.143(3) of the Income Tax Act, 1961 for both the assessment years and made additions towards transactions reported by the DGFT. Since

Harish Chandiram Navrangani, Aurangabad vs. Commissioner of Income Tax(Appeals), Delhi

In the result, appeal of the assessee is allowed for statistical purposes

ITA 599/PUN/2025[2018-2019]Status: DisposedITAT Pune16 Oct 2025AY 2018-2019

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Umesh RuparelFor Respondent: Shri Ramnath P. Murkunde
Section 144Section 147Section 250Section 69A

bank account of the assessee held with The Malkapur Urban Cooperative Bank Limited. Due to non compliance, ld. AO passed Best Judgment Assessment and made addition for the total amount of cash deposit and assessed income at Rs.2,19,51,080/-. Though the assessee filed appeal before ld.CIT

Yakin Jayantilal Shah, Ahmedabad vs. ITO, Ward 2(1)(1), Ahmedabad

ITA 1296/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad15 Oct 2025AY 2017-18

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

For Appellant: Shri Veerabadram Vislavath, Sr.DR
Section 139(1)Section 144BSection 147Section 250

with the Assessing Officer and without the assessee’s participation. The appellate authority, therefore, considered it appropriate to refer to the nature of “best judgment assessment” contemplated under section 144 of the Act. The relevant statutory provision was reproduced, and it was emphasized that such assessments are to be framed ... Finance Act, 2024, by which section 251 of the Act was amended to empower the Commissioner (Appeals) to set aside a best judgment assessment made under section 144 and remit the matter to the Assessing Officer for fresh adjudication. After discussing the legislative background and intent of this amendment

Yakin Jayantilal Shah, Ahmedabad vs. ITO, Ward 2(1)(1), Ahmedabad

ITA 1295/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad15 Oct 2025AY 2016-17

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

For Appellant: Shri Veerabadram Vislavath, Sr.DR
Section 139(1)Section 144BSection 147Section 250

with the Assessing Officer and without the assessee’s participation. The appellate authority, therefore, considered it appropriate to refer to the nature of “best judgment assessment” contemplated under section 144 of the Act. The relevant statutory provision was reproduced, and it was emphasized that such assessments are to be framed ... Finance Act, 2024, by which section 251 of the Act was amended to empower the Commissioner (Appeals) to set aside a best judgment assessment made under section 144 and remit the matter to the Assessing Officer for fresh adjudication. After discussing the legislative background and intent of this amendment

Yakin Jayantilal Shah, Ahmedabad vs. ITO, Ward 2(1)(1), Ahmedabad

ITA 1294/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad15 Oct 2025AY 2015-16

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

For Appellant: Shri Veerabadram Vislavath, Sr.DR
Section 139(1)Section 144BSection 147Section 250

with the Assessing Officer and without the assessee’s participation. The appellate authority, therefore, considered it appropriate to refer to the nature of “best judgment assessment” contemplated under section 144 of the Act. The relevant statutory provision was reproduced, and it was emphasized that such assessments are to be framed ... Finance Act, 2024, by which section 251 of the Act was amended to empower the Commissioner (Appeals) to set aside a best judgment assessment made under section 144 and remit the matter to the Assessing Officer for fresh adjudication. After discussing the legislative background and intent of this amendment

Yakin Jayantilal Shah, Ahmedabad vs. ITO, Ward 2(1)(1), Ahmedabad

ITA 1293/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad15 Oct 2025AY 2014-15

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

For Appellant: Shri Veerabadram Vislavath, Sr.DR
Section 139(1)Section 144BSection 147Section 250

with the Assessing Officer and without the assessee’s participation. The appellate authority, therefore, considered it appropriate to refer to the nature of “best judgment assessment” contemplated under section 144 of the Act. The relevant statutory provision was reproduced, and it was emphasized that such assessments are to be framed ... Finance Act, 2024, by which section 251 of the Act was amended to empower the Commissioner (Appeals) to set aside a best judgment assessment made under section 144 and remit the matter to the Assessing Officer for fresh adjudication. After discussing the legislative background and intent of this amendment

Yakin Jayantilal Shah, Ahmedabad vs. ITO, Ward2(1)(1), Ahmedabad

ITA 1292/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad15 Oct 2025AY 2013-14

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

For Appellant: Shri Veerabadram Vislavath, Sr.DR
Section 139(1)Section 144BSection 147Section 250

with the Assessing Officer and without the assessee’s participation. The appellate authority, therefore, considered it appropriate to refer to the nature of “best judgment assessment” contemplated under section 144 of the Act. The relevant statutory provision was reproduced, and it was emphasized that such assessments are to be framed ... Finance Act, 2024, by which section 251 of the Act was amended to empower the Commissioner (Appeals) to set aside a best judgment assessment made under section 144 and remit the matter to the Assessing Officer for fresh adjudication. After discussing the legislative background and intent of this amendment

Cognizance Constructions Private Limited, Hyderabad vs. ITO., Ward-1(1), Hyderabad

In the result, appeal of the Assessee is allowed for

ITA 344/HYD/2025[2013-14]Status: DisposedITAT Hyderabad15 Oct 2025AY 2013-14

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं / Ita No.344/Hyd/2025 निर्धारण वर्ष/Assessment Year 2013-2014 | M/S. Cognizance | Constructions Private | Limited, Hyderabad. | Pin – 500 075. Telangana. | Pan Aadcc1366M | (Appellant) Vs. The Income Tax Officer, Ward-1(1), Hyderabad. Telangana. (Respondent) निर्धारिती द्वारा/Assessee By: Ca Srinivas Maddury राजस्व द्वारा / Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख /Date Of Hearing: 13.10.2025 घोषणा की तारीख /Pronouncement: 15.10.2025 आदेश/Order Per Vijay Pal Rao: This Appeal By The Assessee Is Directed Against The Order Dated 17.12.2024 Of The Learned Cit(A)-National Faceless Appeal Centre [In Short “Nfac], Delhi, For The

For Appellant: CA Srinivas MadduryFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 139Section 142(1)Section 144Section 147Section 148Section 250Section 271(1)(b)Section 271(1)(c)Section 271ASection 271F

well as notices issued u/sec.142(1) of the Act. Accordingly, the Assessing Officer proceeded to frame the assessment as best Judgment assessment u/sec.144 of the Income Tax Act, 1961. The Assessing Officer assessed the total income of the assessee comprising of business and professional income of Rs.86

Eknath Shankarrao Kawarkhe, Maharashtra vs. Ngp-W-(102)(2), Nagpur

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 410/NAG/2025[2014-2015]Status: DisposedITAT Nagpur14 Oct 2025AY 2014-2015

Bench: Shri Pavan Kumar Gadaleeknath Shankarrao Kawarkhe, 1, Jaipur, B.O. Washim -444507, ……………. Appellant Maharashtra, Pan-Cippk2836K V/S I T O Ward 10(2), Bsnl Rtc Building, ……………. Respondent Civil Lines,Nagpur-444000, Maharashtra.

For Appellant: Ms.Madhavi Joshi, A.RFor Respondent: Shri Surjit Kumar Saha, Sr.DR
Section 144Section 147Section 148Section 151Section 69A

compliance. Whereas the Assessing Officer has considered the information on record and invoked the provisions of section 144 of the Act and made best judgment assessment by making addition of unexplained money u/sec 69A of the Act and assessed the total income of Rs.48,91,000/– and passed order u/sec

Deputy Commissioner of Income-Tax, Central Circle-3, Jaipur vs. Sapna Karnani, Tonk Phatak

In the result, the appeals of the revenue in ITA No

ITA 712/JPR/2025[2017-18]Status: DisposedITAT Jaipur14 Oct 2025AY 2017-18
For Appellant: Shri Deepak Sharma, CAFor Respondent: Ms. Alka Gautam, CIT, DR
Section 127Section 139(1)Section 153ASection 153CSection 68Section 69C

partial restoration of this power was made vide Finance Act (No.2) of 2024, effective 01.10.2024, it was confined exclusively to cases of best judgment assessments under Section 144. This careful legislative design leaves no manner of doubt that except in such limited cases, the CIT(A) cannot remand or direct

Deputy Commissioner of Income-Tax, Central Circle-3, Jaipur vs. Sapna Karnani, Tonk Phatak

In the result, the appeals of the revenue in ITA No

ITA 709/JPR/2025[2013-14]Status: DisposedITAT Jaipur14 Oct 2025AY 2013-14
For Appellant: Shri Deepak Sharma, CAFor Respondent: Ms. Alka Gautam, CIT, DR
Section 127Section 139(1)Section 153ASection 153CSection 68Section 69C

partial restoration of this power was made vide Finance Act (No.2) of 2024, effective 01.10.2024, it was confined exclusively to cases of best judgment assessments under Section 144. This careful legislative design leaves no manner of doubt that except in such limited cases, the CIT(A) cannot remand or direct

Sunil Kumar Agarwal, Jaipur vs. Assistant Commissioner of Income Tax, Central Circle-2, Jaipur

ITA 521/JPR/2025[2020-21]Status: DisposedITAT Jaipur14 Oct 2025AY 2020-21

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, \nvk;dj vihy la-@ITA Nos.513 & 519 to 521/JP/2025\nfu/k Zkj.k o\"kZ@Assessment Years : 2016-17 & 2018-19 to 2020-21\n\nSunil Kumar Agarwal\n395, Narnoli Mansion, Outside\nSanganeri Gate, Jaipur\ncuke\nVs.\nACIT,\nCentral Circle-2,\nJaipur\nLFkk;h y s[kk l a-@thvkb Zvkj la-@PAN/GIR No.: ABRPA9601M\nvihykFkhZ@Appellant i zR;Fkh Z@Respondent\n\nvk;dj vihy la-@ITSS No. 03/JP/2025\nfu/k Zkj.k o\"kZ@Assessment Year : 2015-16\

For Appellant: Shri S. L. Poddar, AdvFor Respondent: Mrs. Anita Rinesh, JCIT, Sr-DR
Section 132Section 139Section 153ASection 234B

under:- "In estimating any escaped turnover, it is inevitable that there is some guesswork. The assessing authority while making the best judgment assessment, no doubt, should arrive at his conclusion without any bias and on a rational basis. That authority should not be vindictive or capricious. If the estimate made ... under:- "11. It is well-settled that in a best judgment assessment, there is always a certain degree of guess work. No doubt the authorities concerned should try to make an honest and fair estimate of the income even in a best judgment assessment, and should not act totally arbitrarily

Sunil Kumar Agarwal, Jaipur vs. Assistant Commissioner of Income Tax, Central Circle-2, Jaipur

In the result the appeal of the assessee in ITA no

ITA 519/JPR/2025[2018-19]Status: DisposedITAT Jaipur14 Oct 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, \nvk;dj vihy la-@ITA Nos.513 & 519 to 521/JP/2025 \nfu/k Zkj.k o"kZ@Assessment Years : 2016-17 & 2018-19 to 2020-21\n\nSunil Kumar Agarwal \n395, Narnoli Mansion, Outside \nSanganeri Gate, Jaipur \ncuke \nVs. \nACIT, \nCentral Circle-2, \nJaipur \nLFkk;h y s[kk la-@thvk Zvkj la-@PAN/GIR No.: ABRPA9601M \nvihykFkhZ@Appellant \ni zR;Fkh Z@Respondent\n\n\nvk;dj vihy la-@ITSS No. 03/JP/2025 \nfu/kZkj.k o"kZ@Assessment Year

For Appellant: Shri S. L. Poddar, AdvFor Respondent: Mrs. Anita Rinesh, JCIT, Sr-DR
Section 132Section 139Section 153ASection 234B

under:- "In estimating any escaped turnover, it is inevitable that there is some guesswork. The assessing authority while making the best judgment assessment, no doubt, should arrive at his conclusion without any bias and on a rational basis. That authority should not be vindictive or capricious. If the estimate made ... under:- "11. It is well-settled that in a best judgment assessment, there is always a certain degree of guess work. No doubt the authorities concerned should try to make an honest and fair estimate of the income even in a best judgment assessment, and should not act totally arbitrarily