Appeal partly allowed, adjustments made to tax amounts, revenue's cross-objections dismissed.

The tribunal partly allowed the appeal, setting aside the addition of Rs. 26,00,00,000 and upholding the deletion of Rs. 2,39,00,000. The cross-objections by the revenue were dismissed.

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Issues Involved:
1. Condonation of delay in filing the appeal.
2. Legality of invoking provisions of Section 153A of the Income Tax Act.
3. Validity of the assessment order without prior approval from the competent authority.
4. Consideration of the affidavit withdrawing the admission made under Section 132(4).
5. Admissibility of revised computation of income.
6. Addition of Rs. 26,00,00,000 as additional income.
7. Addition of Rs. 2,39,00,000 as unexplained cash deposits.

Detailed Analysis:

1. Condonation of Delay:
The assessee's appeal suffered a delay of three days due to the Covid-19 pandemic. Citing the case laws of Collector Land Acquisition vs. Mst. Katiji & Ors and University of Delhi vs. Union of India, the tribunal condoned the delay, considering it neither intentional nor deliberate but due to circumstances beyond control.

2. Invocation of Provisions of Section 153A:
The assessee contested the invocation of Section 153A, arguing no incriminating material was found during the search. The CIT(A) rejected this argument, noting the search was conducted, and the assessee filed a return admitting additional income of Rs. 26,00,00,000. Since it was not a concluded assessment, the tribunal upheld the CIT(A)'s decision to invoke Section 153A.

3. Validity of Assessment Order Without Prior Approval:
The assessee argued that the assessment order was passed without obtaining prior approval from the competent authority under Section 153D. The tribunal did not find merit in this argument and upheld the CIT(A)'s decision.

4. Consideration of Affidavit Withdrawing Admission Under Section 132(4):
The assessee retracted the statement given under Section 132(4) by filing an affidavit, claiming the declaration was incorrect upon verification of records. The CIT(A) rejected the retraction, noting the assessee's inconsistent conduct and lack of acceptable reasons for revising the computation. The tribunal observed that mere admission under Section 132(4) is not conclusive evidence and cited various case laws supporting the principle that only real income should be taxed.

5. Admissibility of Revised Computation of Income:
The assessee submitted a revised computation of income during assessment proceedings, declaring correct income at Rs. 31,62,080. The CIT(A) did not accept this revised computation, citing inconsistent conduct by the assessee. The tribunal, however, noted that the admission made by the assessee is not conclusive evidence for addition. The tribunal allowed the revised computation, emphasizing the principle of taxing only real income.

6. Addition of Rs. 26,00,00,000 as Additional Income:
The tribunal found no basis for the addition of Rs. 26,00,00,000 as there was no detailed declaration during the search. The tribunal cited various case laws and CBDT circulars, concluding that the addition was erroneous. The tribunal set aside the CIT(A)'s order and allowed the grounds raised by the assessee, emphasizing that only real income should be taxed.

7. Addition of Rs. 2,39,00,000 as Unexplained Cash Deposits:
The CIT(A) deleted the addition of Rs. 2,39,00,000 made by the AO towards unexplained cash deposits. The tribunal upheld the CIT(A)'s decision, noting that the assessee had sufficient cash balances on the date of deposit, which were not rejected by the lower authorities. The tribunal dismissed the cross-objections raised by the revenue on this issue.

Conclusion:
The tribunal partly allowed the appeal filed by the assessee, setting aside the addition of Rs. 26,00,00,000 and upholding the deletion of Rs. 2,39,00,000. The cross-objections filed by the revenue were dismissed.

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