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    <description>A prior best judgment assessment does not prevent reopening under section 16 where later material shows systematic under-totalling and suppression in purchases and sales, making the earlier estimate inadequate. The Tribunal accepted jurisdiction to make a further assessment, but confined the escaped turnover addition to an overall fair estimate of 10 per cent of disclosed sales and excluded overlap with additions already sustained in appeal. Penalty was also considered justified because the defects indicated wilful understatement rather than a mere accounting error, but it had to be calculated only on the tax attributable to the sustained additional turnover, resulting in substantial reduction.</description>
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      <link>https://www.taxtmi.com/caselaws?id=68883</link>
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