Assessee's appeal partly allowed, Rs. 5 lakh addition sent for verification, Rs. 88.57 lakh confirmed as undisclosed income.

The appeal of the assessee was partly allowed, with the issue regarding the addition of Rs. 5,00,000/- being restored to the AO for verification, while other additions totaling Rs. 88,57,000/- were confirmed as income from undisclosed sources.

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Issues Involved:
1. Jurisdiction and validity of the impugned order.
2. Addition of Rs. 21,53,000/- and Rs. 20,00,000/- as unexplained cash credit.
3. Addition of Rs. 10,00,000/- deposited through account payee cheque.
4. Addition of Rs. 5,00,000/- from HDFC Bank.
5. Addition of Rs. 1,20,000/- given by the son of the assessee.
6. Addition of Rs. 50,000/- without proper evidence.
7. Addition of Rs. 15,000/- and Rs. 14,000/- as unexplained deposits.
8. Addition of Rs. 1,00,000/- as undisclosed interest income.
9. General grounds concerning the assessed income and procedural errors.

Detailed Analysis:

1. Jurisdiction and Validity of the Impugned Order:
The assessee's ground that the impugned order is against facts, law, and without jurisdiction was dismissed as it was general in nature.

2. Addition of Rs. 21,53,000/- and Rs. 20,00,000/- as Unexplained Cash Credit:
The Assessing Officer (AO) noted various deposits in the assessee's bank accounts and required an explanation for the source. The assessee claimed these amounts were received from two different individuals through agreements to sell property. However, the AO found discrepancies and contradictions in the agreements and the assessee's statements. The CIT (Appeals) upheld the AO's view, concluding that the assessee's story was concocted to justify the deposits, and confirmed the addition of Rs. 21,53,000/- and Rs. 20,00,000/- as income from undisclosed sources.

3. Addition of Rs. 10,00,000/- Deposited Through Account Payee Cheque:
The assessee claimed this amount was transferred from PNB, Dehradun. However, the CIT (Appeals) found no such transfer in the bank statements. The assessee's attempt to provide new evidence before the Tribunal was not accepted as it was not presented to the authorities below. The addition was confirmed due to the failure to discharge the onus of proving the source.

4. Addition of Rs. 5,00,000/- from HDFC Bank:
The assessee claimed this amount was from cash withdrawals of Rs. 8,50,000/- from HDFC Bank. The AO observed that the same amount was re-deposited, making the source unexplained. The CIT (Appeals) upheld this view. However, the Tribunal found merit in the assessee's plea and restored the issue to the AO for verification.

5. Addition of Rs. 1,20,000/- Given by the Son of the Assessee:
The assessee claimed this amount was received from his son through account payee cheques. The AO added the amount back due to the lack of confirmation or evidence. The CIT (Appeals) upheld this addition, noting the failure to establish the creditworthiness and genuineness of the transaction. The Tribunal agreed, dismissing the ground.

6. Addition of Rs. 50,000/- Without Proper Evidence:
The AO found contradictions in the assessee's explanations regarding this deposit. The CIT (Appeals) upheld the addition due to the lack of evidence. The Tribunal also dismissed the ground as the assessee failed to provide any confirmation or evidence.

7. Addition of Rs. 15,000/- and Rs. 14,000/- as Unexplained Deposits:
The AO found these deposits unexplained as the assessee could not provide satisfactory explanations or evidence. The CIT (Appeals) upheld the additions. The Tribunal agreed, noting the failure to discharge the onus of proving the source.

8. Addition of Rs. 1,00,000/- as Undisclosed Interest Income:
The AO estimated the interest income due to the non-disclosure by the assessee. The CIT (Appeals) upheld this estimation. The Tribunal agreed, noting the assessee's failure to provide the requisite information.

9. General Grounds Concerning the Assessed Income and Procedural Errors:
The assessee's general grounds regarding the assessed income and procedural errors were dismissed as they were found to be general in nature without specific merit.

Conclusion:
The appeal of the assessee was partly allowed, with the issue regarding the addition of Rs. 5,00,000/- being restored to the AO for verification, while other additions were confirmed. The order was pronounced in the open court on November 25, 2011.

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