Protective additions in reassessment fail without substantive basis in any other taxpayer's hands.

Protective additions for unexplained cash credits and estimated commission could not be sustained where no corresponding substantive addition existed in any other assessee's hands. The Tribunal applied the principle that a protective assessment is permissible only when there is genuine doubt about the correct person assessable, but reassessment cannot be used merely to safeguard revenue without a substantive basis. The protective additions were deleted.

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Issues: Whether additions made on a protective basis towards unexplained cash credits and estimated commission, without any corresponding substantive addition in any other hand, could be sustained in reassessment proceedings.

Analysis: The Tribunal noted that the impugned additions were made only on a protective basis and that no substantive addition had been shown to exist in any other assessee's hands. It relied on the principle that a protective assessment may be made only where there is doubt as to the correct person assessable, but reassessment cannot be initiated merely to protect the Revenue's interest in the absence of a substantive basis.

Conclusion: The protective additions were not sustainable and were deleted.

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