https://www.taxtmi.com/caselaws?id=782031 ITAT Delhi (AT) allowed the assessee's appeal and deleted the protective additions relating to alleged accommodation entry transactions and commission income. It held that while protective assessments are permissible when there is doubt about in whose hands income is taxable, such protection presupposes existence of a corresponding substantive addition in some other case. As no substantive addition was shown or discussed by the Revenue, the protective assessment lacked legal foundation. Relying on SC and HC precedents, the Tribunal further held that sections 147/148 cannot be invoked merely to protect Revenue's interest. en-us Tue, 04 Nov 2025 00:00:00 +0530 Mon, 24 Nov 2025 08:57:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782031 ITAT Delhi (AT) allowed the assessee's appeal and deleted the protective additions relating to alleged accommodation entry transactions and commission income. It held that while protective assessments are permissible when there is doubt about in whose hands income is taxable, such protection presupposes existence of a corresponding substantive addition in some other case. As no substantive addition was shown or discussed by the Revenue, the protective assessment lacked legal foundation. Relying on SC and HC precedents, the Tribunal further held that sections 147/148 cannot be invoked merely to protect Revenue's interest. Case-Laws Income Tax Tue, 04 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782031