The established case law in Israel holds that the invalidation of a taxpayer's books, or even the absence of any bookkeeping system, does not allow the tax authority to arbitrarily determine the taxpayer's tax liability. The tax authority is obligated to conduct a reasonable assessment, taking into account the specific data of the business and the nature of the business.

The text goes on to emphasize that the tax authority should exercise its authority to determine a judgment-based assessment not out of a desire to punish the taxpayer, but out of a commitment to collect accurate taxes. Even in the absence of documentation, the tax authority should not determine an assessment arbitrarily.

In Israeli Income Tax Circular 2/2012, "Documentation for the Recognition of Expenses and/or the Demanding of Costs," in the section dealing with invoices issued illegally, it is written that if the taxpayer does not meet the burden of proof, the tax authority will assess the taxpayer's income on the basis of economic surveys, estimates, and prevailing norms in the industry in which the taxpayer operates, in accordance with the instructions published by the Israel Tax Authority and with the assistance and support of the authority's economists.