Electronic filing records can sustain reassessment where password misuse allegations remain unproven and turnover data is unrebutted.

Electronic filing records showing the assessee's turnover supported the reassessment, and an unproven allegation that a tax consultant misused the assessee's password did not displace that data. The court treated the alleged misuse as an internal dispute between the assessee and the consultant, and held that pending proceedings against the consultant did not undermine the unrebutted turnover reflected in the electronic records. On that basis, the reassessment and consequential tax liability were upheld, and the writ petition failed, with the assessee left to pursue the statutory appellate remedy.

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Issues: Whether the reassessment and consequential tax demand based on electronic filing data could be sustained despite the assessee's plea that its tax consultant misused the password and carried on business in the assessee's name.

Analysis: The reassessment was founded on EFS data showing the assessee's turnover. The plea of misuse of password by the tax consultant was treated as an internal dispute between the assessee and the consultant. The pendency of proceedings against the consultant did not displace the turnover reflected in the electronic data, and the revenue could not be made to suffer on that basis. The assessments were therefore not shown to be vitiated.

Conclusion: The reassessment and tax liability were upheld.

Final Conclusion: The writ petition failed, while leaving the petitioner free to pursue the statutory appellate remedy.

Ratio Decidendi: A reassessment based on electronic records cannot be displaced merely by an unestablished allegation that a third party misused the assessee's credentials, especially when the turnover reflected in the records remains unrebutted.

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