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ITAT allowed appeal regarding protective addition u/s 68 where cash credits from Trust Chairman were added to assessee trust's income. Tribunal held protective addition unsustainable as substantive assessment in Managing Trustee's hands commenced only on 29.1.2020, after protective addition dated 29.12.2018. Following Supreme Court precedent in Lalji Haridas, protective additions require prior substantive assessment, not vice versa. Protective addition deleted entirely. Regarding disallowance of trustee's travel expenses for NIIT training sessions in Hyderabad, matter remitted to CIT(A)/NFAC for fresh adjudication after assessee produces supporting evidence including tickets, vouchers, and demonstrates business nexus with trust activities.
ITAT allowed appeal regarding protective addition u/s 68 where cash credits from Trust Chairman were added to assessee trust's income. Tribunal held protective addition unsustainable as substantive assessment in Managing Trustee's hands commenced only on 29.1.2020, after protective addition dated 29.12.2018. Following Supreme Court precedent in Lalji Haridas, protective additions require prior substantive assessment, not vice versa. Protective addition deleted entirely. Regarding disallowance of trustee's travel expenses for NIIT training sessions in Hyderabad, matter remitted to CIT(A)/NFAC for fresh adjudication after assessee produces supporting evidence including tickets, vouchers, and demonstrates business nexus with trust activities.
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