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Judgment
PER SATBEER SINGH GODARA, JM
This revenue’s appeal for assessment year 2011-12, arises against the Commissioner of Income Tax (Appeals) [in short, the “CIT(A)”], Delhi-23’s DIN and order no. ITBA/APL/S/250/2025-26/1080175045(1), dated 29.08.2025 involving proceedings under section 143(3) r.w.s. 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).
Heard both the parties. Case file perused.
It is noticed at the outset with the able assistance coming from both the parties that the Revenue’s sole substantive ground herein seeks to revive “protective” additions of Rs. 6,43,28,400/- made on the basis of alleged accommodation entries coupled with section 69B addition amounting to Rs. 4,18,83,274/- ; in the assessee’s hands as deleted in the lower appellate discussion.
It is in this factual backdrop that the Revenue could hardly dispute that the learned CIT(A) had deleted the impugned twin protective addition(s) for the sole reason that the corresponding substantive additions already stood confirmed in Shri Satyender Kumar Jain hands. Hon’ble Apex Court in Lalji Haridas Vs. ITO (1961) 43 ITR 387 (SC) has settled the issue long back that purpose of a “protective” addition is only to safeguard interest of the Revenue. We thus see no merit in Revenue’s grounds pleaded in this appeal seeking to revive the impugned “protective” additions herein in very terms. Rejected accordingly.
No other ground or argument has been pressed before us.
This Revenue’s appeal ITA Nos. 7031/Del/2025 is dismissed.