Tax authorities frequently employ indirect methods, such as bank inflow tests, to determine business turnover when accounting documents are deemed incomplete under Article 29, paragraph (3) of the KUP Law. In the case of PT BSJS, the Respondent made significant revenue corrections based on credit mutations in Bank M and B accounts that the Taxpayer could not explain in detail. The core conflict lies in the burden of proof; the Respondent believed these mutations represented sales, while PT BSJS argued they were loans, book transfers, and prior-year receivables, yet failed to provide valid supporting documents for each transaction.
The Board of Judges resolved to uphold most of the corrections because PT BSJS failed to meet the material burden of proof during the trial to debunk the cash flow findings. This analysis shows that while SE-65/PJ/2013 states cash discrepancies are not automatically business turnover, the absence of credible source documents makes the tax authorities' assumptions legally robust. In conclusion, administrative discipline over every bank mutation, including non-sales supporting documents, is non-negotiable for Taxpayers to avoid ex-officio revenue corrections.
A Comprehensive Analysis and the Tax Court Decision on This Dispute Are Available Here
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