No Protective Addition When Substantive Addition Sustained: ITAT Surat

ACIT Vs Payal Properties Pvt. Ltd. (ITAT Surat)

No Double Addition for Same Income – ITAT Surat Upholds Deletion of Protective Additions

Revenue appealed against CIT(A)’s deletion of protective additions of ₹3.95 crore & ₹1.45 crore made in the case of M/s Payal Properties Pvt. Ltd., representing payments routed through M/s I.B. Enterprises & M/s Dashmesh Developers. AO had made these additions on a protective basis, pending determination of substantive liability in the cases of the other two entities.

Tribunal noted that the substantive additi

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