Protective addition fails once substantive addition is quashed, leaving no basis for assessment.

A protective addition cannot survive on its own once the corresponding substantive addition in the connected case has been quashed. Applying that settled principle, the Tribunal held that the protective addition in the assessee's hands had no independent basis and was not sustainable. It was therefore deleted.

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Issues: Whether the protective addition made in the assessee's hands could survive after the substantive addition in the connected case was quashed.

Analysis: The Tribunal noted that the substantive addition in the connected matter had already been set aside. It applied the settled principle that a protective addition is contingent upon the survival of a substantive addition and cannot stand independently once the substantive addition ceases to exist.

Conclusion: The protective addition was not sustainable and was deleted.

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