Protective Additions Must Be Evidence-Backed: ITAT Deletes Foreign Account Claim

DCIT Vs Shriti Verma (ITAT Delhi)

The Revenue filed four appeals for assessment years 2011-12, 2012-13, 2013-14, and 2014-15 challenging the CIT(A)’s orders deleting protective additions made under section 153A read with section 143(3). The lead appeal concerned a protective addition of ₹45,17,24,929, which the Assessing Officer had added on the basis that the assessee and her mother were beneficial owners of two bank accounts of Master Expert Investment Ltd. with Julius Baer & Co. Ltd., Singapore. The Assessing Officer had stated that substantive additions would be made un

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