2004 (2) TMI 318

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..... ssment period 1985-86 to 1994-95 and 1st April, 1995 to 7th Dec., 1995. 2. Shri V. Ramachandran, the learned counsel for the assessee, submitted that the Assessing Officer (AO) has made an addition of Rs. 51,96,706 on protective basis. The learned counsel further submitted that the substantive addition has been confirmed by the AO in the case of Shri P. Uttamchand. Once the substantive addition .....

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..... sides, we also perused the material available on record. Admittedly, the addition is made on the protective basis. The assessee has challenged before this Tribunal only in respect of the addition made on protective basis. It is not in dispute that the very same addition was made substantively in the case of Shri P. Uttamchand. There is no specific provision in the IT Act for the purpose of making .....

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