Assessable value cannot rest on balance sheet figures alone when resale transactions are supported by invoices and no corroboration exists.

Assessable value cannot be enhanced merely by relying on balance sheet figures where the assessee explains the difference as resale transactions and produces supporting purchase and sale invoices. The recorded quantities showed trading clearances of goods bought from outside and sold as such, and the Department failed to produce corroborative evidence that the balance sheet reflected amounts other than resale value. In the absence of such material, the basis for treating the balance sheet figures as an independent measure of assessable value was not established, and the Department's approach was rejected.

---

---

Issues: Whether the assessable value could be determined by relying on figures in the balance sheet when the assessee explained that the difference arose from resale transactions and supporting invoices were produced.

Analysis: The balance sheet figures were explained by the assessee through purchase and sale invoices placed before the adjudicating authority, and the recorded quantity was shown to include trading clearances of goods purchased from outside and sold as such. The Department did not place sufficient evidence to show that the balance sheet reflected amounts other than resale value. In the absence of corroborative material, the basis for enhancing the assessable value was not established.

Conclusion: The appeal failed and the Department's case for adopting the balance sheet figures as an independent basis for assessable value was rejected.

---