2016 (10) TMI 975

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..... o not find any substantial question of law arises in respect of protective income as assessed by the Assessing Officer. However, if the substantive assessment is set aside in Appeal or otherwise, revenue would have liberty to seek revival of the present proceedings. The remaining amount of ₹ 15,45,000/-, which is the subject matter of appeal, is less than the monetary limit in respect of .....

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..... the assessment year 1997-98. 3. In the aforesaid case, the Assessing Officer made an assessment holding that the assessee is liable to pay tax on income of ₹ 3,52,35,130/- including protective income of ₹ 3,33,54,503/-. The income on protective assessment was set aside by the Commissioner of Income Tax (Appeal) and upheld by the Income Tax Appellate Tribunal. 4. It is conceded b .....

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