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2018 (6) TMI 1700 - AT - Income TaxUndisclosed income - Unexplained deposits in bank account - as per the ITS information, AO came to know that the assessee has deposited in Kotak Mahindra Bank for acquiring bonds/debenture - CIT(A) was of the view that the assessment has to be made on substantive basis in the case of the assessee as the assessee is having his own business and has been filing regular return of income and convinced that the addition of ₹ 1 lakhs - HELD THAT:- Bench asked the ld. DR to furnish the details of substantive additions made in the hands of Shri Ajay Taneja or any other person. The ld. DR could not furnish such details. On the other hand, he pointed out that no substantive additions have been made in the hands of any other member of the Taneja Group. In our considered opinion, if no substantive additions have been made in any other hands, there is no room for addition to be made on protective basis in the hands of the assessee. In our considered view, there cannot be any protective assessment without there being a substantive assessment. We, therefore, decline to interfere with the finding of the ld. CIT(A). - Decided against revenue.
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