CHANDRA REDDY, C.J.

In this case, the Sales Tax Appellate Tribunal allowed the appeal of the respondent on the ground that the formula adopted by the department had no basis, although the Deputy Commissioner of Commercial Taxes had jurisdiction to revise the assessment made by the assessing authority.

We do not think this conclusion of the Tribunal could be assailed before us. Obviously, the assessment is based on a guess work. The only ground that could be urged in support of the proposal to revise the assessment is that month after month the assessee was showing losses which could not have been the case and that he would not have continued the business was there such loss every month. We do not think that this conjecture could be a justification for seeking to revise the order of the assessing authority.

If the Deputy Commissioner could on the material before him find data for revising the assessment, it is open to him to do so. It must be made clear that he has no jurisdiction to travel beyond the record that is available to the assessing authority. The basis should be found on the record already in existence. This does not, however, preclude the assessing authority itself