Appeals partly allowed, AO to re-examine additions. Unexplained income upheld. Challenges to reassessment dismissed.

The Tribunal partly allowed the appeals, directing the AO to re-examine the quantification of additions and correct any mathematical errors. The addition of unexplained income of Rs. 30,00,000/- was upheld due to the assessee's failure to explain the entries. Challenges to reassessment proceedings were dismissed as infructuous.

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Issues Involved:
1. Legality and jurisdiction of the CIT(A) and assessment order.
2. Consideration of submissions and case laws by the CIT(A).
3. Addition of unexplained income based on entries in Annexure A-1 and A-4.
4. Reassessment proceedings under sections 147/148.
5. Mathematical errors in the calculation of additions.
6. Onus of explaining the nature and source of credit entries.

Detailed Analysis:

1. Legality and Jurisdiction of CIT(A) and Assessment Order:
The assessee challenged the legality, jurisdiction, and validity of the CIT(A) and assessment orders for AY 2007-08 and 2012-13. The Tribunal noted that these grounds were general and dismissed them as infructuous.

2. Consideration of Submissions and Case Laws by CIT(A):
The assessee claimed that the CIT(A) failed to consider their submissions and the ratios of various case laws. The Tribunal found that the CIT(A) had summarized the facts and submissions of the assessee but upheld the additions made by the AO. The Tribunal did not find any specific infirmity in the CIT(A)'s approach.

3. Addition of Unexplained Income Based on Entries in Annexure A-1 and A-4:
The AO added Rs. 126,28,85,990/- and Rs. 30,00,000/- as unexplained income based on entries in Annexure A-1 and A-4. The assessee argued that these entries were accommodation entries for which only commission income should be taxed. The Tribunal noted that the assessee failed to provide names and addresses of the parties involved and did not disclose any commission income in their returns. The Tribunal partly allowed the appeal, directing the AO to quantify the additions by considering only one side of the transactions (either incoming or outgoing funds) and to exclude cheque numbers and daily opening balances from the addition.

4. Reassessment Proceedings Under Sections 147/148:
For AY 2007-08, the assessee challenged the reassessment proceedings, claiming non-compliance with the GKN Driveshaft case dictum and improper disposal of objections. The Tribunal noted that the assessee did not press these grounds during the hearing and dismissed them as infructuous.

5. Mathematical Errors in the Calculation of Additions:
The assessee pointed out factual inaccuracies and mathematical errors in the calculation of the unexplained income. The Tribunal directed the AO to re-examine the calculations and make necessary corrections, ensuring that only the correct amounts are added.

6. Onus of Explaining the Nature and Source of Credit Entries:
The assessee failed to discharge the onus of explaining the nature and source of credit entries amounting to Rs. 30,00,000/- from three persons. The Tribunal upheld the CIT(A)'s decision to confirm these additions, as the assessee did not provide any confirmations or complete addresses of the parties involved.

Conclusion:
The Tribunal partly allowed the appeals for statistical purposes, directing the AO to re-examine the quantification of additions and correct any mathematical errors. The addition of Rs. 30,00,000/- was upheld due to the assessee's failure to explain the entries. The reassessment proceedings challenges were dismissed as infructuous.

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