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

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