https://www.taxtmi.com/caselaws?id=443327 The Tribunal held that protective additions are substitutive in nature and made to protect the revenue's interest. When substantive addition does not survive due to being time-barred, protective addition also does not stand. The Tribunal ruled in favor of the appellant, deleting the interest addition under Section 244(A). The reassessment proceedings against the partners being time-barred led to the deletion of the protective addition made in the hands of the assessee firm. The judgment emphasizes the separate tax entities of partners and firms, the significance of protective additions, and the impact of time-barred reassessment proceedings on additions in the assessee's hands. en-us Tue, 19 Sep 2023 00:00:00 +0530 Thu, 21 Sep 2023 13:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=443327 The Tribunal held that protective additions are substitutive in nature and made to protect the revenue's interest. When substantive addition does not survive due to being time-barred, protective addition also does not stand. The Tribunal ruled in favor of the appellant, deleting the interest addition under Section 244(A). The reassessment proceedings against the partners being time-barred led to the deletion of the protective addition made in the hands of the assessee firm. The judgment emphasizes the separate tax entities of partners and firms, the significance of protective additions, and the impact of time-barred reassessment proceedings on additions in the assessee's hands. Case-Laws Income Tax Tue, 19 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=443327