(1.) HEARD counsel for the petitioner and Government Pleader for respondent. The main grievance of the petitioner is fixation of gross profit at 15% for taxable goods because gross profit for non-taxable goods returned by the petitioner was 15%. Counsel for the petitioner rightly pointed out that without the officer establishing with material that accounts are unreliable, there is no scope for rejection of books of accounts and estimation of turnover. Government Pleader pointed out that petitioner has also not explained the difference in pattern of gross profit in taxable goods at two branches, one at Calicut and the other at Kochi. After hearing both sides, we feel that the issue decided by the Tribunal is only a question of fact and after 20 years of relevant year, there is no scope for remanding the matter. We therefore dismiss the S.T. Revision as devoid of any merit.