https://www.taxtmi.com/caselaws?id=294598 Protective assessment cannot be confirmed in appeal as a substitute for determining the correct person chargeable to tax. Where the substantive addition in the assessee's hands had already been deleted and the Revenue did not challenge that deletion, there was no basis to retain the corresponding protective addition. The Tribunal held that an appellate authority must decide real chargeability rather than sustain an alternative assessment without supporting substantive tax liability. The protective addition sustained by the CIT(A) was therefore vacated, while the relief on the substantive addition remained undisturbed. en-us Wed, 13 Apr 2011 00:00:00 +0530 Fri, 23 Apr 2021 16:33:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=294598 Protective assessment cannot be confirmed in appeal as a substitute for determining the correct person chargeable to tax. Where the substantive addition in the assessee's hands had already been deleted and the Revenue did not challenge that deletion, there was no basis to retain the corresponding protective addition. The Tribunal held that an appellate authority must decide real chargeability rather than sustain an alternative assessment without supporting substantive tax liability. The protective addition sustained by the CIT(A) was therefore vacated, while the relief on the substantive addition remained undisturbed. Case-Laws Income Tax Wed, 13 Apr 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=294598