The CIT(Appeals) upheld the additions, finding that the assessee failed to substantiate the source of funds and the donor's creditworthiness. The tribunal admitted additional evidence filed by the assessee and remanded the matter to the CIT(Appeals) for reconsideration.

The tribunal held that additions on an estimation basis cannot be made without rejecting the books of account under Section 145(3) of the Act. Since the AO did not reject the books of account, the ad-hoc additions were deemed unjustified and arbitrary.

The Tribunal held that the earlier order quashing the Section 263 assessments was effective, as there was no stay from the High Court. Consequently, the appeals filed by the revenue were deemed infructuous.

The Tribunal noted that although the department had appealed to the High Court, there was no stay of proceedings. Therefore, the ITAT concluded that the order dated June 30, 2025, was effective and that the current appeals filed by the Revenue had become infructuous.

The Tribunal noted that the ITAT order from 30th June 2025, quashing the Section 263 orders, was effective as there was no stay from the High Court. Consequently, the appeals filed by the Revenue were rendered infructuous.

The Tribunal held that since its earlier order quashing the Section 263 order was still effective, the department's appeals were rendered infructuous. Consequently, all appeals filed by the Revenue were dismissed.

The Tribunal noted that the ITAT's previous order quashing the Section-263 orders was effective as there was no stay from the High Court. Consequently, the appeals filed by the Revenue were rendered infructuous.

The Tribunal noted that while the department had approached the High Court, there was no stay granted. Therefore, the ITAT's earlier order remained effective. Consequently, all appeals filed by the Revenue were deemed infructuous and dismissed.

The Tribunal held that since the order quashing the Section 263 orders was effective and no stay was granted by the High Court, the appeals filed by the Revenue had become infructuous. Consequently, all appeals filed by the Revenue were dismissed.

The Tribunal held that the reassessment notice under section 148 was issued beyond the prescribed 'surviving time' as per the directions of the Hon'ble Apex Court and the jurisdictional High Court of Gujarat in the case of Dhanraj Govindram Kella. Therefore, the notice was invalid and barred by limitation.

The Tribunal noted that the assessment order was contradictory as it was framed under Section 143(3) but the AO had rejected the books of accounts, indicating a proceeding under Section 144. Since no proper adjudication was made by the AO, the matter was restored back to the AO for a fresh assessment.

The tribunal held that the second reopening of assessment was bad in law as it was based on a change of opinion and lacked tangible material. Furthermore, the addition of the entire bank deposits without considering the nature of transactions and without applying the peak credit principle was unsustainable.

The Tribunal held that a notice issued under Section 148 of the Act, which is neither manually nor digitally signed, is invalid. This defect violates statutory mandates and is not curable, rendering the notice and subsequent reassessment proceedings void. The Tribunal followed the jurisdictional High Court's decisions on similar matters.

The Tribunal noted that while complete documentation was not provided, the assessee's auditors had verified the books of account and concluded the cash deposits were from regular business. Therefore, the Tribunal allowed 50% of the cash deposit, i.e., Rs. 14 lacs, as arising from liquor business.

The Tribunal accepted the prayer of the assessee's Authorized Representative. The appeal was dismissed as withdrawn.

The Tribunal held that the impugned cash deposits were sourced from the assessee's sales proceeds, which were supported by sales invoices and VAT returns. The assessee had also offered income on a presumptive basis under section 44AD, and the bank account was part of the financial statements. Therefore, the addition made by the AO was deleted.