Protective Addition Cannot Survive Once Substantive Addition Is Taxed Elsewhere: ITAT Delhi

ACIT Vs B R R Securities Pvt. Ltd. (ITAT Delhi) Protective Addition Cannot Survive Once Substantive Addition Is Taxed Elsewhere: ITAT Grants Relief to Conduit Company The Delhi ITAT upheld the deletion of additions made in the hands of B R R Securities Pvt. Ltd., holding that where the Revenue itself treats a company merely as a conduit for routing accommodation entries and has already taxed the substantive income in the hands of the alleged entry operators, no separate protective addition can be sustained in the hands of the conduit company. The case arose from a search conducted on the Jain ...