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Protective addition made by Assessing Officer was not sustainable as substantive addition did not survive in concluded assessment proceedings of related party. CIT(A) rightly deleted protective addition as per settled law that if substantive addition does not survive, protective addition also does not survive, as held in Pr. CIT (Central)-2 vs. Electrical and Electronic India Ltd. Revenue's appeal dismissed as no interference warranted with CIT(A)'s order deleting protective addition in absence of incriminating material and substantive addition in related party's case.
Protective addition made by Assessing Officer was not sustainable as substantive addition did not survive in concluded assessment proceedings of related party. CIT(A) rightly deleted protective addition as per settled law that if substantive addition does not survive, protective addition also does not survive, as held in Pr. CIT (Central)-2 vs. Electrical and Electronic India Ltd. Revenue's appeal dismissed as no interference warranted with CIT(A)'s order deleting protective addition in absence of incriminating material and substantive addition in related party's case.
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