Non-filing of appeal changes character of protective additions to substantive additions

DCIT Vs M/s Nirala Housing Pvt. Ltd. (ITAT Delhi) Conclusion: When an assessee accepts the protective additions made in assessment order by not filing any appeal against it, the character of the additions changes from protective addition to substantive addition. Held: NHPL and NDPL were companies in Nirala Group. AO computed undisclosed incomes against assessees after search operation conducted in the premises of the companies. One of the two assessees, NHPL, instead of substantiating the manner in which undisclosed income was derived, actually took a contrary stand, in contradiction of the di...