Protective Addition Under Section 69A Is Temporary and Deleted Once Substantive Reassessment Is Done

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....The ITAT held that a protective addition under section 69A is temporary and intended to safeguard Revenue's interest when the real owner of income is uncertain. Once a substantive addition of the same amount is made in the hands of the actual owner through reassessment under sections 147 read with 144/144B, maintaining the protective addition against the initial assessee lacks justification. Consequently, the Tribunal deleted the protective addition from the assessee's assessment. The appeal filed by the assessee was allowed accordingly.....