Tribunal grants relief on appeal, upholding deletions and remanding depreciation issue for further verification.

The tribunal partially allowed the appeal, granting relief on various grounds. The tribunal upheld deletions related to unexplained capital sourced from liquidated FDRs, sundry creditors based on reasonable profit estimation, and agricultural income share. Additionally, deletions were made for unexplained marriage gifts and expenses, adhoc disallowance of expenses, and a difference in the value of construction, citing completion over two years and no additions in prior assessments. The issue of disallowed depreciation was remanded for further verification by the AO. The delay in pronouncing the order was attributed to the COVID-19 lockdown, following the JSW Ltd case precedent.

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Issues Involved:
1. Unexplained Capital
2. Sundry Creditors under Section 68
3. Disallowance of Depreciation
4. Agricultural Income
5. Marriage Gift
6. Marriage Expenses
7. Adhoc Disallowance of Expenses
8. Difference in Value of Cost of Construction

Detailed Analysis:

1. Unexplained Capital:
The assessee introduced Rs. 352,000 as fresh capital. The AO added this amount as unexplained, but the CIT(A) deleted the addition related to marriage gift and agricultural income, sustaining only Rs. 112,500. The tribunal found that the assessee had liquidated FDRs with Tata Finance, providing a source for the capital. Consequently, the tribunal deleted the sustained addition of Rs. 112,500.

2. Sundry Creditors under Section 68:
The AO disallowed Rs. 1,71,850 as unexplained sundry creditors. The CIT(A) sustained this addition. The tribunal observed that the profit declared by the assessee in the travel business was reasonable and directed the AO to estimate the total income at 10% of the travel business, thereby deleting the addition of sundry creditors.

3. Disallowance of Depreciation:
The AO disallowed Rs. 1,54,091 in depreciation due to the lack of purchase bills. The assessee submitted additional evidence before the tribunal. The tribunal remitted this issue back to the AO to verify the genuineness of the purchase bills and allow the depreciation if found proper.

4. Agricultural Income:
The AO added Rs. 72,850 as unexplained agricultural income. The CIT(A) allowed Rs. 9,167 based on the share of the assessee in the agricultural land. The tribunal found no new material or documents and upheld the CIT(A)'s findings.

5. Marriage Gift:
The AO added Rs. 2,14,150 as unexplained cash credit for marriage gifts. The CIT(A) sustained Rs. 1,64,150. The tribunal accepted an affidavit from the mother-in-law confirming the gifts and directed the AO to delete this addition.

6. Marriage Expenses:
The AO estimated marriage expenses at Rs. 1,00,000, adding Rs. 52,500 as unexplained expenditure. The CIT(A) sustained this addition. The tribunal noted that the assessee's mother had withdrawn Rs. 50,000 from a postal account and directed the AO to delete this addition, recognizing the common practice of receiving gifts in Indian marriages.

7. Adhoc Disallowance of Expenses:
The AO disallowed 20% of expenses in the proprietary concerns, amounting to Rs. 1,63,374. The CIT(A) directed the AO to allow verifiable expenses. The tribunal observed that the profit declared by the assessee was reasonable and directed the AO to estimate the total income from the travel business at 10%, thereby deleting the adhoc disallowance.

8. Difference in Value of Cost of Construction:
The AO added Rs. 3,88,000 based on a valuation report from the DVO. The CIT(A) sustained this addition. The tribunal found that the construction was completed over two years and that the reassessment for AY 2005-06 did not result in any addition. The tribunal accepted the assessee's submission and directed the AO to delete this addition.

Conclusion:
The tribunal allowed the appeal partly, providing relief on several grounds while remanding the issue of depreciation back to the AO for verification. The tribunal's decision was influenced by the additional evidence submitted and the common practices in Indian marriages. The order was pronounced beyond the standard 90-day period due to the COVID-19 lockdown, following the precedent set by the JSW Ltd case.

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