Estimated assessment based on comparable traders need only disclose the basis of the estimate, not exhaustive business details.

Where an assessee's accounts are found unreliable, the taxing authority may reject them and determine profits by estimate based on comparable cases. The assessee is entitled only to sufficient indication of the basis of that estimate, such as the gross profit range of comparable traders and the profit rate of a similar business. The authority need not supply exhaustive particulars of the comparables' turnover, contracts, or business methods, because that would make assessment impracticable and is not required to inform the assessee of the grounds of the estimate. On that approach, detailed disclosure about the comparable merchants was not required.

---

---

Issues: Whether, in an application for reference arising from an estimated assessment based on comparable cases, the assessee was entitled to detailed information about the business of the comparable merchants before the estimate could be sustained.

Analysis: The accounts maintained by the assessee were found unreliable, so the taxing authority was entitled to reject them and determine profits by estimate. The basis of the estimate had been indicated to the assessee to the extent reasonably necessary, including the range of gross profits shown by comparable cloth dealers and the profit rate of a merchant carrying on similar business. The assessee could not insist on exhaustive particulars about the turnover, contracts, and business methods of the comparable merchants, because such a requirement would make assessment unworkable and was not required for apprising him of the basis of the estimate.

Conclusion: The assessee was not entitled to detailed information regarding the comparable cases, and the application for reference was dismissed against the assessee.

---