If there is substantive addition as well as protective addition in the case of same assessee for different assessment year, how will that be covered? Similarly if there is substantive addition in case of one assessee and protective addition on same issue in the case of another assessee, how will that be covered under Vivad se Vishwas?

Guidance on Resolving Substantive and Protective Additions Under Direct Tax Vivad Se Vishwas Act, 2020.

If there is both substantive and protective addition for the same assessee in different assessment years, or if there is substantive addition for one assessee and protective addition on the same issue for another, the Direct Tax Vivad Se Vishwas Act, 2020, provides guidance. Upon settling a dispute involving substantive addition under Vivad se Vishwas, the Assessing Officer will issue a rectification order to delete the protective addition related to the same issue, whether it pertains to the same assessee or another.