https://www.taxtmi.com/caselaws?id=797227 Protective addition under section 69A cannot rest solely on physical possession of jewellery where the same asset has been substantively assessed in the hands of another claimed owner. Physical possession is relevant but does not establish actual or beneficial ownership without independent positive evidence. A protective assessment is contingent and serves to safeguard revenue only where genuine uncertainty exists regarding the person liable; it cannot be converted into a substantive charge through the assessee's non-compliance. The stated principles support deletion of the protective addition and recomputation of consequential interest. The delay in filing the appeal was treated as condonable where bona fide pursuit of connected remedies established sufficient cause. en-us Fri, 07 Aug 2026 00:00:00 +0530 Wed, 19 Aug 2026 08:20:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797227 Protective addition under section 69A cannot rest solely on physical possession of jewellery where the same asset has been substantively assessed in the hands of another claimed owner. Physical possession is relevant but does not establish actual or beneficial ownership without independent positive evidence. A protective assessment is contingent and serves to safeguard revenue only where genuine uncertainty exists regarding the person liable; it cannot be converted into a substantive charge through the assessee's non-compliance. The stated principles support deletion of the protective addition and recomputation of consequential interest. The delay in filing the appeal was treated as condonable where bona fide pursuit of connected remedies established sufficient cause. Case-Laws Income Tax Fri, 07 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797227