Post-year inspection material can support turnover assessment when it reveals suppression during the relevant year.

Post-year inspection material may be relied upon to support assessment where it directly reveals suppression of transactions during the relevant assessment year. The timing of the inspection alone does not make the report unusable, and the fact that it was prepared by an Inspector does not by itself disqualify it. The decisive question is whether the material is connected with the year under assessment and can properly support the turnover estimate. The Tribunal may still examine the correctness of that estimate on the material before it. The reference was answered in favour of the Revenue.

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Issues: Whether an inspection report prepared after the close of the assessment year could be utilised to support assessment for that year when it disclosed suppression of transactions during the relevant year.

Analysis: A discrepancy or suppression detected after the expiry of the assessment year is not to be discarded merely because the inspection occurred later, if the material relates to the assessment year in question. The fact that the report was prepared by an Inspector does not by itself render it unusable. What matters is whether the detected suppression is connected with the year under assessment and whether the material can properly support the assessment or estimate of turnover. The Tribunal remains competent to examine the correctness of the estimate on the material before it.

Conclusion: The reference is answered in favour of the Revenue. The Tribunal was not justified in holding that the report could not be utilised for assessment year 1975-76 merely because the inspection was made after the close of that year.

Final Conclusion: Post-year inspection material that directly discloses suppression during the relevant assessment year may be relied upon in assessing turnover, subject to the Tribunal's power to test the correctness of the estimate on remand.

Ratio Decidendi: Material discovered after the close of the assessment year is admissible for that year's assessment if it is directly connected with suppression during the relevant year; the timing of inspection alone does not exclude its use.

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