State-wise turnover segregation required before reassessment where online ticket data may have included multiple states.

Assessment based on third-party online bus-ticket data was challenged on the ground that the turnover adopted may not have been confined to Andhra Pradesh and may have included operations in Telangana, Tamil Nadu and Puducherry. The High Court accepted the explanation on the officer's competence and tax-circle restructuring, but found the record unclear on whether the assessed turnover was restricted to the petitioner's Andhra Pradesh business. It therefore set aside the assessment and penalty order, and permitted the petitioner to produce segregated state-wise turnover records for fresh consideration and reassessment after hearing.

---

---

Issues: Whether the impugned assessment and penalty order was liable to be set aside for want of jurisdiction and for failing to confine the turnover to the State of Andhra Pradesh, and whether the matter required fresh assessment after giving the petitioner an opportunity to produce segregated turnover records.

Analysis: The assessment was based on third-party data obtained from online bus-ticket platforms and the core controversy was whether that material reflected turnover only attributable to Andhra Pradesh or also included turnover from Telangana, Tamil Nadu and Puducherry. The authority's explanation regarding restructuring of the tax circles and the competence of the officer passing the order was accepted, but the record did not clarify whether the turnover adopted for assessment was restricted to the petitioner's Andhra Pradesh operations. In these circumstances, the Court found it appropriate to permit the petitioner to place state-wise turnover data before the assessing authority, with a corresponding opportunity to pass a reconsidered order in accordance with law after hearing the petitioner.

Conclusion: The impugned assessment order was set aside and the petitioner was granted liberty to furnish segregated state-wise turnover records for fresh consideration and reassessment.

---