An appellate authority cannot, after finding the...

An appellate authority cannot, after finding the unexplained-expenditure provision inapplicable, delegate determination of the gross-profit rate and consequential addition to the Assessing Officer. Any gross-profit addition must rest on a reasoned determination and cannot be mechanically applied to disputed purchases that include capitalised items without examining genuine comparables, alleged inflation, and differential margins; fresh speaking adjudication is required. Penalty for furnishing inaccurate particulars does not arise merely because a disclosed bad-debt write-off or unpaid-interest claim is disallowed. Where audited accounts, ledgers, liability, and payment details were disclosed, and no falsity, fabrication, suppression, or deliberate inaccuracy was established, penalty is deleted despite a tax-audit reporting error. Recorded assessment satisfaction can validate penalty initiation despite a common notice.