Assessing Officer's Protective Assessment Without Substantive Assessment is Unsustainable; Risks Time-Barred Issues.

The concept of protective assessment also becomes important in a situation where the addition on substantive basis is deleted and in such an event, protective assessment shall change its colour by becoming substantive assessment. Had there not been such protective assessment, then assessment with respect to such person (protective assessment) would have become barred by time. - The protective assessment framed by the AO without making the substantive assessment is not sustainable. - AT .....

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