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The ITAT held that a protective addition under section 69A is temporary and intended to safeguard Revenue's interest when the real owner of income is uncertain. Once a substantive addition of the same amount is made in the hands of the actual owner through reassessment under sections 147 read with 144/144B, maintaining the protective addition against the initial assessee lacks justification. Consequently, the Tribunal deleted the protective addition from the assessee's assessment. The appeal filed by the assessee was allowed accordingly.
The ITAT held that a protective addition under section 69A is temporary and intended to safeguard Revenue's interest when the real owner of income is uncertain. Once a substantive addition of the same amount is made in the hands of the actual owner through reassessment under sections 147 read with 144/144B, maintaining the protective addition against the initial assessee lacks justification. Consequently, the Tribunal deleted the protective addition from the assessee's assessment. The appeal filed by the assessee was allowed accordingly.
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