263 Revision Invalid: Protective Assessment Permissible When Substantive Addition Already Done

Nishan Inbuild Ltd. Vs PCIT (ITAT Delhi) Section 263 Revision Quashed – Protective Assessment Valid When Substantive Addition Already Made in Key Person’s Case The Delhi ITAT allowed the assessee’s appeal and quashed the revision order passed by the PCIT under Section 263, holding that the original assessment could not be treated as erroneous or prejudicial to the interests of the Revenue. The Tribunal noted that in search proceedings under Section 153C, the Assessing Officer had made additions of unexplained cash credits and commission income in the assessee’s hands only on a protecti...