https://www.taxtmi.com/caselaws?id=796074 Protective additions based on the same facts, evidence and conclusions as corresponding substantive additions cannot be retained once the substantive additions are deleted. The notes state that such additions also fail where the underlying material lacks evidentiary value and does not reliably establish alleged commission income or the taxpayer's involvement. For the relevant assessment years, jurisdictional precedent on the validity of proceedings was considered applicable in the absence of any distinguishing factual or legal basis. The stated principle is that deletion of substantive additions and absence of credible supporting evidence preclude protective additions. en-us Wed, 27 May 2026 00:00:00 +0530 Fri, 31 Jul 2026 08:27:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796074 Protective additions based on the same facts, evidence and conclusions as corresponding substantive additions cannot be retained once the substantive additions are deleted. The notes state that such additions also fail where the underlying material lacks evidentiary value and does not reliably establish alleged commission income or the taxpayer's involvement. For the relevant assessment years, jurisdictional precedent on the validity of proceedings was considered applicable in the absence of any distinguishing factual or legal basis. The stated principle is that deletion of substantive additions and absence of credible supporting evidence preclude protective additions. Case-Laws Income Tax Wed, 27 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796074