https://www.taxtmi.com/caselaws?id=796074 Protective additions based on the same facts, evidence and conclusions as corresponding substantive additions cannot survive once the substantive additions are deleted and the related assessments are quashed. Where the underlying material lacks evidentiary value and does not establish alleged commission receipts or the assessee's involvement, protective assessments are unsustainable. For the relevant assessment years, applicable jurisdictional precedent on the validity of proceedings further prevented retention of the additions where no distinguishing factual or legal basis existed. The combined effect is that protective additions must be deleted when neither the substantive assessment nor reliable evidence supports the alleged income. 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 survive once the substantive additions are deleted and the related assessments are quashed. Where the underlying material lacks evidentiary value and does not establish alleged commission receipts or the assessee's involvement, protective assessments are unsustainable. For the relevant assessment years, applicable jurisdictional precedent on the validity of proceedings further prevented retention of the additions where no distinguishing factual or legal basis existed. The combined effect is that protective additions must be deleted when neither the substantive assessment nor reliable evidence supports the alleged income. Case-Laws Income Tax Wed, 27 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796074