TaxTMI 
TaxTMI 
2023 (4) TMI 1265
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....Aggarwal, Adv. For the Revenue : Sh. T. James Singson, CIT DR ORDER PER DR. B. R. R. KUMAR, ACCOUNTANT MEMBER: These appeals have been filed by the revenue against the order of the ld CIT(A)-XXVI, New Delhi dated 13.11.2017 for Assessment Years 2010-11 to 2012-13. 2. The revenue has raised the following grounds of appeal:- "I. Whether Ld. CIT(A) has erred on facts and in law in deleting the....
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.... been made on substantive basis in JP Minda Group Companies (AO para 11.2). 4. The protective addition has been deleted by the ld CIT(A). 5. Aggrieved the revenue filed appeal before us. 6. Before us the ld DR argued that once the additions made on substantive basis are deleted, the addition made on protective basis comes alive. For the sake of ready reference the arguments of the ld. DR in wri....
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....under rule 27 of the ITAT Rules submitted on 02/03/2023 3) Comments given by AO with regard to assesses application under rule 27 of ITAT rules may be taken into consideration. With regard to Para-1 above. (Protective assessment deleted by CIT(A) for 3 A.Ys.) In this regard is to submit that, the Ld CIT(A) in his order has not appreciated nor considered any of the facts and reasonings recorded....
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...., due to the reasons explained, the order of the Ld CIT(A) is wrong and not accepted by the revenue and accordingly it is requested to be quashed. The Revenue fully relies on the Order passed by the AO and the same may kindly be restored. For the sake of repetition it is also submitted that, if in case the substantive basis addition is deleted the protective basis assessment comes alive." 7. Th....