TMI Blog2018 (6) TMI 1700X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 mad ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... )-XXV, New Delhi dated 21.10.2011 pertaining to A.Y 2008-09. 2. The solitary grievance of the Revenue is that the ld. CIT(A) has erred in deleting the addition of ₹ 73.85 lakhs made by the Assessing Officer on account of undisclosed income held by the Assessing Officer. 3. Briefly stated, the facts of the case are that as per the ITS information, the Assessing Officer came to know ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nduct a business or to pay the alleged payments. Accordingly, the Assessing Officer made the addition of ₹ 74,85,500/- in the hands of the assessee on protective basis. 4. The assessee strongly agitated the matter before the ld. CIT(A). After considering the facts and submissions, the ld. CIT(A) was of the view that the assessment has to be made on substantive basis in the case of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n 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). 7. In the result, the appeal of the Revenue is dismissed. The order is pronounced in the open co ..... X X X X Extracts X X X X X X X X Extracts X X X X
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