When Substantive Addition is Time-Barred, Protective Addition Also Fails

Kanav Metals Vs ITO (ITAT Delhi) In the case of Kanav Metals vs. ITO (Income Tax Appellate Tribunal, Delhi), the central issue revolves around a protective addition made by the Income Tax Officer (ITO) and the subsequent dispute over the time-barred substantive addition. Here is a detailed analysis of this matter: 1. Background: Kanav Metals, the appellant, filed its income tax return for the assessment year 2014-15, declaring an income of Rs. 12,220. The company was involved in wholesale scrap business. 2. Protective Addition: During the assessment process, the ITO noticed an addition of Rs. ...