Third-party web data mismatch cannot by itself sustain assessment without proper verification and procedure.

Assessments based solely on mismatch data extracted from third-party websites or web portals are unsafe where they are made without a proper procedural framework and meaningful verification. The text states that an earlier Madras HC decision had already rejected such one-sided reliance and required a centralized mechanism before the dealer is called upon to explain discrepancies. On that basis, the impugned assessment was treated as unsustainable and a fresh assessment was directed under the revised procedure, while the attachment was continued pending reassessment.

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Issues: Whether an assessment made by relying on mismatch details taken from the websites and web portals of other entities, without following a proper procedure, could be sustained, and whether the impugned assessment order was liable to be set aside with a fresh assessment directed.

Analysis: The assessment was founded on a comparison of the assessee's returns with data available in the websites of other dealers. The Court noted that an earlier decision had already disapproved such a one-sided and unsafe method of assessment and had indicated the need for a proper centralized mechanism before calling upon the dealer to explain the mismatch. That principle was treated as governing the field. On that basis, the impugned assessment was held to be unsustainable, while the attachment was permitted to continue until a fresh adjudication was completed under the new methodology.

Conclusion: The impugned assessment order was set aside and the respondent was directed to make a fresh assessment after the new procedure became operative. The petitioner succeeded to that extent, though the matter was left open for reassessment and the attachment was continued in the meantime.

Final Conclusion: The writ petition resulted in annulment of the existing assessment and a direction for de novo assessment under the revised procedure, with interim protection of revenue by continuation of the attachment.

Ratio Decidendi: An assessment based solely on third-party web data mismatch, without a proper procedural framework and meaningful verification, is unsafe and cannot be sustained.

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