Addition on protective basis not justified when AO already taxed on substantive basis

ACIT Vs Siyaram Gupta (HUF) (ITAT Allahabad) Conclusion: Once the substantive assessment in the case of Mr. Siya Ram Gupta was confirmed , the protective assessment had no independent standing but dependent on the final outcome of the substantive assessment. CIT(A) was right for deleting the addition on protective basis on the ground that AO had already taxed the same in the hands of Mr. Siya Ram Gupta on substantive basis. Held: Assessee for assessment year 2003-04 was assessed on protective basis to the tune of Rs. 70,000/- by AO, vide assessment order dated 29.03.2006 passed u/s 143(3), as ...