Protective additions based on alleged accommodation entries in wool trading could not survive after the substantive addition in M/s RNB Overseas Pvt. Ltd. was deleted on merits; the related commission addition, being only consequential, also failed. The Tribunal further held that bank deposit additions in completed assessments could not be made under search-assessment powers without seized incriminating material, and bank accounts or statements not found in the search were insufficient for that purpose. Deletions of both the protective and bank deposit additions were therefore upheld, and the Revenue's appeals were dismissed.
Protective additions based on alleged accommodation entries in wool trading could not survive after the substantive addition in M/s RNB Overseas Pvt. Ltd. was deleted on merits; the related commission addition, being only consequential, also failed. The Tribunal further held that bank deposit additions in completed assessments could not be made under search-assessment powers without seized incriminating material, and bank accounts or statements not found in the search were insufficient for that purpose. Deletions of both the protective and bank deposit additions were therefore upheld, and the Revenue's appeals were dismissed.
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