No Justification for Protective Tax Additions on Shareholders When Overseas Companies Already Accounted as Residents in India.

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....Protective addition - when addition was already made in the hands of the overseas companies on substantive basis treating them as residents in India, there is no justification for the Assessing Officer to make such an addition in the hands of a share holder on protective basis, when no benefit was derived by her from these companies to protect the interest of revenue. - AT....