Tribunal upholds CIT(A)'s decisions, dismisses Revenue's appeals on unexplained cash & FDR interest.

The Tribunal dismissed all three appeals by the Revenue for Assessment Years 2011-12, 2017-18, and 2015-16, upholding the decisions of the CIT(A) in deleting the additions related to unexplained cash and accrued interest on FDRs. The Tribunal found that the additions lacked incriminating material and were not justified, affirming the CIT(A)'s decisions based on consistent findings and prior considerations by the Settlement Commission.

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Issues Involved:
- Appeal against order of Commissioner of Income Tax (Appeals) for Assessment Years 2011-12, 2017-18, and 2015-16.
- Time-barred appeals by the Revenue.
- Addition on account of unexplained cash under section 69A of the Income Tax Act 1961.
- Deletion of addition on account of accrued interest on Fixed Deposit Receipts (FDRs).
- Interpretation of provisions under section 153C read with section 143(3) of the Act.
- Application of proviso to section 79 of the Act regarding change in shareholding pattern.

Analysis:

Assessment Year 2011-12:
- The Revenue filed an appeal against the CIT(A)'s order for the Assessment Year 2011-12, challenging the deletion of additions related to unexplained cash and accrued interest on FDRs.
- The Revenue's appeal was time-barred by two days, but the delay was condoned.
- The CIT(A) deleted the additions based on findings that were consistent with a previous decision involving a related entity within the same group.
- The Tribunal upheld the CIT(A)'s decision, citing that the amount in question had already been considered in the income of the assessee and other entities before the Settlement Commission.
- The Tribunal dismissed the Revenue's appeal, affirming the CIT(A)'s decision on both issues.

Assessment Year 2017-18:
- The Revenue appealed against the CIT(A)'s order for the Assessment Year 2017-18, challenging the deletion of additions related to unexplained cash under section 69A.
- The appeal was initially time-barred by 10 days, but the delay was condoned due to reasons explained by the Departmental Representative.
- The Tribunal dismissed the Revenue's appeal, applying the same reasoning and decision as in the Assessment Year 2011-12.

Assessment Year 2015-16:
- The Revenue appealed against the CIT(A)'s order for the Assessment Year 2015-16, challenging the deletion of additions related to unexplained cash under section 69A and invoking section 79 of the Act.
- The appeal was initially time-barred by 130 days, but the delay was condoned based on valid reasons.
- The Tribunal dismissed the Revenue's appeal, maintaining that the additions made by the Assessing Officer lacked incriminating material and were not justified in the absence of such evidence.
- The Tribunal rejected the argument of abated assessment and upheld the CIT(A)'s decision to delete the additions.
- The Tribunal dismissed the Revenue's appeal for this assessment year as well.

In conclusion, the Tribunal dismissed all three appeals by the Revenue for Assessment Years 2011-12, 2017-18, and 2015-16, upholding the decisions of the CIT(A) in deleting the additions on various grounds.

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