https://www.taxtmi.com/caselaws?id=800585 Section 251(1)(a), during the relevant period, required the first appellate authority to confirm, reduce, enhance or annul an assessment; after rejecting section 69C, it could not leave an unspecified gross-profit rate for the assessing officer to determine. A reasoned gross-profit addition required identification of the rate, its basis, comparable transactions and quantum, and could not be mechanically applied to capitalised purchases or staff-uniform expenditure. Penalty for concealment or inaccurate particulars required more than a deduction disallowance where audited accounts, ledgers and payment particulars disclosed the claim. Failure to satisfy bad-debt conditions or section 43B's actual-payment requirement, without false or inaccurate particulars, did not itself establish a penalty default. en-us Fri, 25 Sep 2026 00:00:00 +0530 Thu, 08 Oct 2026 08:45:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800585 Section 251(1)(a), during the relevant period, required the first appellate authority to confirm, reduce, enhance or annul an assessment; after rejecting section 69C, it could not leave an unspecified gross-profit rate for the assessing officer to determine. A reasoned gross-profit addition required identification of the rate, its basis, comparable transactions and quantum, and could not be mechanically applied to capitalised purchases or staff-uniform expenditure. Penalty for concealment or inaccurate particulars required more than a deduction disallowance where audited accounts, ledgers and payment particulars disclosed the claim. Failure to satisfy bad-debt conditions or section 43B's actual-payment requirement, without false or inaccurate particulars, did not itself establish a penalty default. Case-Laws Income Tax Fri, 25 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800585