Validity of substantive addition in one year & protective addition in other year

Microsoft Regional Sales Pte. Ltd. Vs ACIT (ITAT Delhi) While in the A.Y. 2018-19, the protective addition has been made in the hands of the assessee and the substantive addition has been made in the Mol Corporation during the A.Y. 2019-20, the substantive addition has been made in the case of assessee as the case of Mol Corporation has not picked up for scrutiny u/s 143(3) by CASS. This led to an oxymoronic situation for the department. The revenue tried to triumph over such situation by imperfectly making the addition in this year in the case of the assessee instead of Mol Corporation. The j...