Protective assessment allows provisional income tax assessments when liability between multiple persons is uncertain, but bars protective recovery or penalties. Protective assessment allows tax authorities to record an alternative income tax assessment where it is indeterminate which of several persons is liable. Such assessments function as provisional paper assessments in situations like pending civil litigation, possible benami arrangements, or suspected diversion of income to relatives where facts are not yet established. While a protective assessment may be made, authorities may not issue protective recovery or penalty orders; the assessment remains conditional until liability is resolved.