Key legal question
Whether the input tax deduction had to be estimated because the taxpayers were assessed on estimated turnover and lacked invoices.
Extracted holding
No. Input tax remains deductible only if the taxpayers prove the taxed input tax by proper evidence; an estimated turnover assessment does not justify an estimated input tax deduction on these facts.
Extracted reasoning
The lack of proof was attributable to the taxpayers themselves, who had systematically disregarded self-assessment and bookkeeping duties and operated in gray-market and illegal channels. They were given the chance to obtain supplier confirmations but did not do so.