Protective addition of the value of seized fine gold was impermissible once actual ownership was established. Since the owners of the seized gold were identified and had admitted ownership, and substantive assessment of the same asset was made in the hands of those real owners who undertook to discharge the tax liability, the assessee's mere status as a job worker could not justify a parallel protective addition. Accordingly, the protective addition in the assessee's hands was held invalid and was deleted, allowing the appeal. - ITAT
Protective addition of the value of seized fine gold was impermissible once actual ownership was established. Since the owners of the seized gold were identified and had admitted ownership, and substantive assessment of the same asset was made in the hands of those real owners who undertook to discharge the tax liability, the assessee's mere status as a job worker could not justify a parallel protective addition. Accordingly, the protective addition in the assessee's hands was held invalid and was deleted, allowing the appeal. - ITAT
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