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    <title>2026 (1) TMI 1539 - ITAT RAJKOT</title>
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    <description>Protective assessment is a temporary safeguard when the taxable person is uncertain; once the real assessee is identified and substantive additions are sustained in that person&#039;s hands, the protective addition must be deleted because the same income cannot be taxed twice. The assessing officer had made substantive additions in the partners&#039; hands which were affirmed on appeal, and the partners accepted liability; accordingly the protective addition assessed against the partnership firm was held redundant and ordered deleted, since allowing both assessments would amount to impermissible double taxation and is not required to protect revenue once the correct assessee is fixed.</description>
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      <title>2026 (1) TMI 1539 - ITAT RAJKOT</title>
      <link>https://www.taxtmi.com/caselaws?id=785783</link>
      <description>Protective assessment is a temporary safeguard when the taxable person is uncertain; once the real assessee is identified and substantive additions are sustained in that person&#039;s hands, the protective addition must be deleted because the same income cannot be taxed twice. The assessing officer had made substantive additions in the partners&#039; hands which were affirmed on appeal, and the partners accepted liability; accordingly the protective addition assessed against the partnership firm was held redundant and ordered deleted, since allowing both assessments would amount to impermissible double taxation and is not required to protect revenue once the correct assessee is fixed.</description>
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      <pubDate>Tue, 20 Jan 2026 00:00:00 +0530</pubDate>
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