The Tribunal held that the CIT(A) had correctly examined the evidences submitted by the assessee, including cash book, sales registers, and RTO registrations, which established that the cash deposits of Rs. 1,75,18,000/- were from the sale of tractors to farmers and were accounted for. The AO had not pointed out specific defects in these evidences and had not conducted further inquiries during the remand proceedings. Therefore, the addition of Rs. 4,08,15,150/- was not sustainable.

The Tribunal held that the original assessment order under section 147 r.w.s. 144 was set aside by the NFAC to the AO. Consequently, the subsequent rectification order under section 154 also became invalid and infructuous.

The Tribunal held that additions made solely on the basis of documents or digital data seized from third parties, without any corroborative evidence found from the assessee's premises, cannot be sustained. Reliance on statements of third parties without allowing cross-examination was also deemed improper. Valuation reports obtained from private individuals and not from the DVO, and reports pertaining to commercial property used for residential property estimations, were also found to have no legal sanctity.

The Tribunal held that the additions for unaccounted plot/SCO sales and unexplained expenditure were to be deleted, as similar issues for the prior year were decided in favor of the assessee and no incriminating material was found. The addition for unaccounted receipts from M/s RIPSS was deleted due to the unsigned nature of the MOU and lack of evidence. The addition for unexplained expenditure on villas was deleted due to lack of specific details and mention of VAT instead of GST.

The Tribunal held that the additions related to unaccounted sales of plots and SCOs were to be deleted as no incriminating material was found during the search, consistent with previous year's decisions. The addition for unexplained expenditure was also deleted based on prior tribunal rulings. The addition for alleged unaccounted receipts from M/s RIPSS was deleted as it was based on an unsigned MOU without corroborative evidence.

The Tribunal held that additions based solely on documents/digital data recovered from third parties, without corroborative evidence found on the assessee's premises or statements from the assessee's representatives, cannot be sustained. Opportunity for cross-examination was also not provided. Valuation reports from private individuals also lacked legal sanctity.

The Tribunal held that separate additions for unaccounted purchases and sales could not be sustained when the two were intrinsically linked. It directed the Assessing Officer to estimate profit on unaccounted sales at 3% for certain assessment years. Certain additions were deleted entirely as they represented advances or were unsubstantiated. The protective additions were also deleted in most cases.

The Tribunal held that separate additions for unaccounted purchases and sales could not be sustained when they were intrinsically linked. It directed the AO to apply a profit element of 3% on unaccounted sales and certain unaccounted purchases. Some additions were deleted entirely, and a protective addition was also deleted.

The Tribunal found that while the assessee firm was involved in both out-of-books purchases and sales, separate additions for both were not sustainable. The Tribunal directed the AO to apply a profit element to the unaccounted sales and deleted certain additions, while partly allowing others. For some years, additions were deleted entirely based on the nexus between purchases and sales.

The Tribunal held that the additions regarding on-money payment for property purchase were unsustainable due to a lack of corroboration and mismatch in property details, relying on a similar ITAT decision. For the unaccounted liquor purchases, the Tribunal found that the presumption under Section 292C of the Income Tax Act was not applicable to the assessee as the incriminating material was found from a third party's premises. It also noted the lack of evidence directly linking the transactions to the assessee and the prohibition under excise laws against unaccounted purchases by wholesalers. The addition related to a property purchase based on an unregistered agreement to sell was also dismissed for lack of validity and evidence of cash payment.

The Tribunal held that the addition for alleged on-money payment for property purchase was not sustainable due to lack of corroboration and mismatch in project details, citing a similar prior ruling. For the addition concerning unaccounted liquor purchases, the Tribunal found that the presumption under Section 292C of the Income Tax Act did not apply to the assessee as the incriminating material was found during a third-party search, and there was no concrete evidence linking the entries to the assessee's specific transactions.