Insufficient documentary evidence barred writ interference with sales tax classification of installation-related receipts as taxable turnover.

Assessment of receipts as taxable turnover was sustained because the assessee failed to produce sufficient documentary material to show that the activity was only installation or interior-decoration services and not a taxable supply of goods. The assessing authority had sought work orders, purchase orders, invoices, detailed work descriptions and other client records, but these were not adequately furnished. On such incomplete material, the Court held that the nature of the transactions could not be reassessed in writ jurisdiction, and the assessment order was left undisturbed with the statutory appeal remedy preserved.

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Issues: Whether the assessment order treating the petitioner's receipts as taxable turnover under the sales tax law could be interfered with in writ jurisdiction when the petitioner failed to produce sufficient material to establish that the activity was only installation and not a taxable supply of goods.

Analysis: The challenge rested on the assertion that the receipts were attributable only to interior decoration services on which service tax had been paid, and that the reassessment was without basis. However, the material sought by the assessing authority, including work orders, purchase orders, detailed descriptions of work, invoices and client-related supporting documents, was not adequately produced. In the absence of such evidence, the authority concluded that the petitioner had not substantiated its plea that the transactions were mere installation or that the goods were supplied only by clients. The Court held that classification of the activity could not be undertaken on incomplete material and that the writ court could not reappreciate the nature of the activity on the basis of such deficient records.

Conclusion: The writ challenge was rejected and the assessment order was left undisturbed.

Final Conclusion: The petitioner failed to establish a factual foundation for interference under writ jurisdiction, and the statutory assessment was sustained, with liberty reserved to pursue the appeal remedy.

Ratio Decidendi: Where the assessee does not place sufficient documentary evidence before the assessing authority to establish the true nature of the transaction, the High Court will not interfere in writ jurisdiction with the assessment based on the available material.

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