Protective addition for alleged bogus purchases was deleted where no direct link to the transactions was shown.

Protective addition for alleged bogus purchases was deleted because the assessee was not directly linked to the impugned transactions in the relevant year, and the assessment record did not show a clear basis for selecting the assessee alone for protective taxation. The deletion was upheld as free from infirmity on the facts recorded. Once the Revenue's challenge failed, the assessee's cross objection became infructuous.

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Issues: Whether the protective addition made in the assessee's hands towards alleged bogus purchases was liable to be deleted.

Analysis: The addition arose from reopening based on alleged accommodation entries in the business of a partnership firm, while the assessee had been assessed only on a protective basis. The record showed that the assessee was not directly linked with the impugned purchase transactions in the relevant year, and the assessment proceeded without any clear basis for selecting the assessee alone for protective taxation. In these circumstances, the order deleting the addition was found free from infirmity. The cross objection did not survive once the Revenue's appeal failed.

Conclusion: The protective addition was rightly deleted and the Revenue's challenge failed; the assessee's cross objection became infructuous.

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