Appellate authority upholds protective tax assessment; ensures tax collection even if substantive assessment fails. No taxpayer harm.

Validity of Addition on protective basis - Although, there is no provision in the Income Tax Act authorizing the levy of income tax on a person other than whom income tax is payable but the object of the protective assessment is that in case substantive addition is made in the hands of other person and in case assessment fails then in that eventuality the Department must get the tax from the person in whose hands protective assessment is made or ultimately if substantive addition made is confirmed then in that eventuality protective addition cannot survive. - no loss is going to suffer by the assessee, in case, we uphold the order of the ld. CIT(A) in upholding the protective addition made by the AO in the hands of the assessee - AT .....

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