Mismatch-based reassessment requires full consideration of assessee's enclosures before a revised assessment can stand.

In a mismatch-based reassessment, the assessing authority must verify the purchase and sale particulars with reference to all materials furnished by the assessee and cannot rely on a truncated set of enclosures. Where the assessee had filed seven seller-wise sale statements in reply to the notice, but the reassessment order addressed only one and gave no indication that the remaining six were considered, the order was procedurally defective. The revised assessment was therefore set aside and the matter remitted for fresh consideration of all relevant enclosures in accordance with law.

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Issues: Whether the revised assessment order could be sustained when, in a mismatch-based reassessment, only one of the several enclosures furnished by the assessee was considered and the remaining enclosures were not adverted to.

Analysis: In a mismatch matter, the assessing authority must undertake a proper verification of the purchase and sale particulars and cannot proceed on a truncated consideration of the materials furnished by the assessee. Where the assessee had enclosed seven sets of seller-wise sale particulars in reply to the notice, but the impugned order dealt with only one set and did not disclose consideration of the other six enclosures, the reassessment was found to be procedurally defective. The order was therefore set aside on the touchstone of the governing mismatch-enquiry principle and the matter was remitted for fresh consideration of the omitted materials in accordance with law.

Conclusion: The revised assessment order was unsustainable and was set aside, with a direction to reconsider the matter afresh after taking into account all the relevant enclosures.

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