Protective Assessment can’t be made against Shareholder If Overseas Companies already been assessed on substantive basis

DCIT Vs. Smt. Mala Kalsi (ITAT Delhi)

We find that AO in the assessment order admitted that the entire amount which was added to the income of the assessee on “protective basis” was already assessed in the hands of the overseas companies on “substantive basis”. It was further noted that the Assessing Officer did not consider the details filed by the assessee in the course of the assessment proceedings but made the assessment of the assessee on the basis of the assessment orders of the overseas companie

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