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“protective assessment”

MiscellaneousAssessmentAssessment441 judgments

The decision most relied on for protective assessment is Lalji Haridas v. ITO (43 ITR 387), cited in 238 judgments on BharatTax.

Leading authorities on protective assessment

Lalji Haridas v. ITO
43 ITR 387 · 1961 · Supreme Court
238
citing judgments

When an assessing authority is uncertain about the true ownership of funds or in whose hands income should be assessed, it can frame a protective assessment to safeguard the Revenue's interest. Such protective assessments remain valid until the substantive assessment is finalized.

CIT, Gujarat II v. Surendra Gulab Chand Modi
140 ITR 517 · 1983 · High Court
88
citing judgments

Protective assessments should not be deleted or disposed of by lower authorities, but rather allowed to remain in effect until the related substantive assessment proceedings attain finality before the High Court or Supreme Court.

DHFL Venture Capital Fund v. ITO
358 ITR 471 · 2013 · High Court
66
citing judgments

Reassessment proceedings cannot be initiated solely for the purpose of making a protective addition. Such proceedings are not valid in the eyes of law.

Bhailal Manilal Patel v. CIT
49 Taxmann.com 539 · 2014 · High Court
47
citing judgments

Penalty under section 271(1)(c) cannot be imposed based on a protective assessment order. Initiation of penalty proceedings is impermissible without a substantive assessment order that finally adds income to the assessee's hands.

Peter Vaz v. Commissioner of Income Tax, Central Circle, Bangalore
128 Taxmann.com 180 · 2021 · High Court
34
citing judgments

An assessee can raise an objection regarding the validity of the Assessing Officer's jurisdiction for reopening a concluded assessment even if the issue was not raised before the CIT(Appeals), by invoking Rule 27 of the Income Tax Appellate Tribunal Rules, 1963. This is permissible if the issue is ancillary to the main issue and does not require additional evidence.

(CIT v. Cochin Co. Pvt. Ltd.
104 ITR 655 · 1976 · High Court
32
citing judgments

A protective assessment is permissible when the assessing officer has doubt regarding who is in receipt of income, but a recovery based on a protective assessment is not allowed. If an assessment is intended to be protective, it must be clearly stated as such.

CIT v. Super Steel (Sales) Co.
178 ITR 451 · 1989 · High Court
28
citing judgments

A penalty under Section 271(1)(c) for concealment of income cannot be levied when the assessment was made on a protective basis, especially if the income was actually assessed in the hands of another person and it was uncertain who had concealed the income.

Suresh K. Jajoo v. ACIT
39 SOT 514 · 2010 · ITAT
27
citing judgments

A protective assessment cannot be made without a prior substantive assessment.

Judgments citing protective assessment

Cmr Technical Education Society, Hyderabad vs. DCIT., Central Circle-2(1), Hyderabad

In the result, the appeal filed by the assessee in ITA

ITA 866/HYD/2025[2019-20]Status: DisposedITAT Hyderabad25 Aug 2025AY 2019-20

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

Section 12A

consider that the Assessing Officer (AO) had already made a "protective addition" of the alleged excess fee in the hands of individual trustees. Protective assessments are only applicable where the ownership of income is uncertain. Therefore, it was inappropriate for the PCIT (Central) to Initiate cancellation proceedings against the society ... educational institutions. Further, the Assessing Officer completed assessment by treating the receipts as "Protective" in the hands of individual trustee and that, the protective assessments are only applicable where the ownership of income is uncertain. Therefore, it was inappropriate for the PCIT (Central) to initiate cancellation proceedings against the society

K M R Educational Society, Hyderabad vs. DCIT., Central Circle-2(1), Hyderabad

In the result, the appeal filed by the assessee in ITA

ITA 865/HYD/2025[2022-23]Status: DisposedITAT Hyderabad25 Aug 2025AY 2022-23

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

Section 12A

consider that the Assessing Officer (AO) had already made a "protective addition" of the alleged excess fee in the hands of individual trustees. Protective assessments are only applicable where the ownership of income is uncertain. Therefore, it was inappropriate for the PCIT (Central) to Initiate cancellation proceedings against the society ... related in the affairs of society in running the educational institutions. the receipts as "Protective" in the hands of individual trustee and that, the protective assessments are only applicable where the ownership of income is uncertain. Therefore, it was inappropriate for the PCIT (Central) to initiate cancellation proceedings against

K M R Educational Society, Hyderabad vs. DCIT., Central Circle-2(1), Hyderabad

In the result, the appeal filed by the assessee in ITA

ITA 864/HYD/2025[2019-20]Status: DisposedITAT Hyderabad25 Aug 2025AY 2019-20

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

Section 12A

consider that the Assessing Officer (AO) had already made a "protective addition" of the alleged excess fee in the hands of individual trustees. Protective assessments are only applicable where the ownership of income is uncertain. Therefore, it was inappropriate for the PCIT (Central) to Initiate cancellation proceedings against the society ... related in the affairs of society in running the educational institutions. the receipts as "Protective" in the hands of individual trustee and that, the protective assessments are only applicable where the ownership of income is uncertain. Therefore, it was inappropriate for the PCIT (Central) to initiate cancellation proceedings against

Marri Educational Society, Hyderabad vs. DCIT., Central Circle-2(1), Hyderabad

In the result, the appeal filed by the assessee in ITA

ITA 863/HYD/2025[2022-23]Status: DisposedITAT Hyderabad25 Aug 2025AY 2022-23

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

Section 12A

consider that the Assessing Officer (AO) had already made a "protective addition" of the alleged excess fee in the hands of individual trustees. Protective assessments are only applicable where the ownership of income is uncertain. Therefore, it was inappropriate for the PCIT (Central) to Initiate cancellation proceedings against the society ... related in the affairs of society in running the educational institutions. the receipts as "Protective" in the hands of individual trustee and that, the protective assessments are only applicable where the ownership of income is uncertain. Therefore, it was inappropriate for the PCIT (Central) to initiate cancellation proceedings against

Marri Educational Society, Hyderabad vs. DCIT., Central Circle-2(1), Hyderabad

ITA 862/HYD/2025[2019-20]Status: DisposedITAT Hyderabad25 Aug 2025AY 2019-20
For Appellant: Shri C. Maheswar Reddy, C.A
Section 12A

consider that the Assessing Officer (AO) had already made a "protective addition" of the alleged excess fee in the hands of individual trustees. Protective assessments are only applicable where the ownership of income is uncertain. Therefore, it was inappropriate for the PCIT (Central) to Initiate cancellation proceedings against the society ... educational institutions. Further, the Assessing Officer completed assessment by treating the receipts as "Protective" in the hands of individual trustee and that, the protective assessments are only applicable where the ownership of income is uncertain. Therefore, it was inappropriate for the PCIT (Central) to initiate cancellation proceedings against the society

Chandramma Educational Society, Hyderabad vs. DCIT., Central Circle-2(1), Hyderabad

In the result, the appeal filed by the assessee in ITA

ITA 861/HYD/2025[2022-23]Status: DisposedITAT Hyderabad25 Aug 2025AY 2022-23

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

Section 12A

consider that the Assessing Officer (AO) had already made a "protective addition" of the alleged excess fee in the hands of individual trustees. Protective assessments are only applicable where the ownership of income is uncertain. Therefore, it was inappropriate for the PCIT (Central) to Initiate cancellation proceedings against the society ... educational institutions. Further, the Assessing Officer completed assessment by treating the receipts as "Protective" in the hands of individual trustee and that, the protective assessments are only applicable where the ownership of income is uncertain. Therefore, it was inappropriate for the PCIT (Central) to initiate cancellation proceedings against the society

Chandramma Educational Society, Hyderabad vs. DCIT., Central Circle-2(1), Hyderabad

In the result, the appeal filed by the assessee in ITA

ITA 860/HYD/2025[2019-20]Status: DisposedITAT Hyderabad25 Aug 2025AY 2019-20

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

Section 12A

consider that the Assessing Officer (AO) had already made a "protective addition" of the alleged excess fee in the hands of individual trustees. Protective assessments are only applicable where the ownership of income is uncertain. Therefore, it was inappropriate for the PCIT (Central) to Initiate cancellation proceedings against the society ... educational institutions. Further, the Assessing Officer completed assessment by treating the receipts as "Protective" in the hands of individual trustee and that, the protective assessments are only applicable where the ownership of income is uncertain. Therefore, it was inappropriate for the PCIT (Central) to initiate cancellation proceedings against the society

M.G.R.Educational Society, Hyderabad vs. DCIT., Central Circle-2(1), Hyderabad

ITA 859/HYD/2025[2022-23]Status: DisposedITAT Hyderabad25 Aug 2025AY 2022-23
Section 12A

consider that the Assessing Officer (AO) had already made a "protective addition" of the alleged excess fee in the hands of individual trustees. Protective assessments are only applicable where the ownership of income is uncertain. Therefore, it was inappropriate for the PCIT (Central) to initiate cancellation proceedings against the society ... educational institutions. Further, the Assessing Officer completed assessment by treating the receipts as "Protective" in the hands of individual trustee and that, the protective assessments are only applicable where the ownership of income is uncertain. Therefore, it was inappropriate for the PCIT (Central) to initiate cancellation proceedings against the society

M.G.R.Educational Society, Hyderabad vs. DCIT, Central Circle-2(1), Hyderabad

ITA 858/HYD/2025[2017-18]Status: DisposedITAT Hyderabad25 Aug 2025AY 2017-18
For Appellant: Shri C. Maheswar Reddy, C.A
Section 12A

consider that the Assessing Officer (AO) had already made a "protective addition" of the alleged excess fee in the hands of individual trustees. Protective assessments are only applicable where the ownership of income is uncertain. Therefore, it was inappropriate for the PCIT (Central) to Initiate cancellation proceedings against the society

Pawan Mechu, Chirawa vs. DCIT Cen Cir 1, Jaipur

ITA 74/JPR/2025[2018-19]Status: DisposedITAT Jaipur14 Aug 2025AY 2018-19

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri Vedant Agarwal, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 132Section 132(1)Section 139Section 143(2)Section 153CSection 69

person amongst two is liable to be assessed, parallel proceedings may be taken against both and (alternative assessments may also be framed, while a protective assessment is permissible, it not open to the appellate authorities to make a protective order. Law does not permit assessment of the same income successively

Pawan Mechu, Jhunjhunu vs. DCIT Cen Cir 1, Jaipur

ITA 1458/JPR/2024[2016-17]Status: DisposedITAT Jaipur14 Aug 2025AY 2016-17

Bench: CIT(A).

For Appellant: Shri Vedant Agarwal, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 132Section 132(1)Section 139Section 143(2)Section 153CSection 69

person amongst two is liable to be assessed, parallel proceedings may be taken against both and (alternative assessments may also be framed, while a protective assessment is permissible, it not open to the appellate authorities to make a protective order. Law does not permit assessment of the same income successively

Deputy Commissioner of Income Tax, Central Circle-2, Trichy vs. No 1 Auto Finance, Karur

In the result, the appeals of the Revenue in ITA Nos

ITA 658/CHNY/2025[2018-19]Status: DisposedITAT Chennai06 Aug 2025AY 2018-19

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.:656 To 658/Chny/2025 धनिाजरण वर्ज / Assessment Years: 2012-13, 2015-16 & 2018-19 Deputy Commissioner Of Income Tax, No.1 Auto Finance, Central Circle – 2, Vs. No.1, Tam Complex, Nrmp Street, Trichy Covai Road, Karur – 639 002. [Pan:Aahfn 3793 J] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) आयकर अपील सं./Ita Nos.:622 & 633/Chny/2025 धनिाजरण वर्ज / Assessment Years: 2012-13 & 2018-19 Deputy Commissioner Of Income Tax, Help Line Motor Finance, Central Circle – 2, Vs. No.1, Tam Complex, Nrmp Street, Trichy Covai Road, Karur – 639 002. [Pan:Aaffh 3971 E] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Ms.E.Pavuna Sundari, Cit प्रत्यथी की ओर से/Respondent By : Shri.R.Venkata Raman, Ca & Shri.R.S.Lakshmi Narayana, Advocate सुनवाई की तारीख/Date Of Hearing : 18.06.2025 घोर्णा की तारीख/Date Of Pronouncement : 06.08.2025

For Appellant: Ms.E.Pavuna Sundari, CITFor Respondent: Shri.R.Venkata Raman, CA &
Section 132Section 143(3)

आयकर अपीलीय अधिकरण, ‘ए’ न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI श्री जॉजज जॉजज के, उपाध्यक्ष

Deputy Commissioner of Income Tax, Central Circle-2, Trichy vs. No 1 Auto Finance, Karur

In the result, the appeals of the Revenue in ITA Nos

ITA 656/CHNY/2025[2012-13]Status: DisposedITAT Chennai06 Aug 2025AY 2012-13

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.:656 To 658/Chny/2025 धनिाजरण वर्ज / Assessment Years: 2012-13, 2015-16 & 2018-19 Deputy Commissioner Of Income Tax, No.1 Auto Finance, Central Circle – 2, Vs. No.1, Tam Complex, Nrmp Street, Trichy Covai Road, Karur – 639 002. [Pan:Aahfn 3793 J] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) आयकर अपील सं./Ita Nos.:622 & 633/Chny/2025 धनिाजरण वर्ज / Assessment Years: 2012-13 & 2018-19 Deputy Commissioner Of Income Tax, Help Line Motor Finance, Central Circle – 2, Vs. No.1, Tam Complex, Nrmp Street, Trichy Covai Road, Karur – 639 002. [Pan:Aaffh 3971 E] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Ms.E.Pavuna Sundari, Cit प्रत्यथी की ओर से/Respondent By : Shri.R.Venkata Raman, Ca & Shri.R.S.Lakshmi Narayana, Advocate सुनवाई की तारीख/Date Of Hearing : 18.06.2025 घोर्णा की तारीख/Date Of Pronouncement : 06.08.2025

For Appellant: Ms.E.Pavuna Sundari, CITFor Respondent: Shri.R.Venkata Raman, CA &
Section 132Section 143(3)

आयकर अपीलीय अधिकरण, ‘ए’ न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI श्री जॉजज जॉजज के, उपाध्यक्ष

Deputy Commissioner of Income Tax, Central Circle-2, Trichy vs. Help Line Motor Finance, Karur

In the result, the appeals of the Revenue in ITA Nos

ITA 633/CHNY/2025[2018-19]Status: DisposedITAT Chennai06 Aug 2025AY 2018-19

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.:656 To 658/Chny/2025 धनिाजरण वर्ज / Assessment Years: 2012-13, 2015-16 & 2018-19 Deputy Commissioner Of Income Tax, No.1 Auto Finance, Central Circle – 2, Vs. No.1, Tam Complex, Nrmp Street, Trichy Covai Road, Karur – 639 002. [Pan:Aahfn 3793 J] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) आयकर अपील सं./Ita Nos.:622 & 633/Chny/2025 धनिाजरण वर्ज / Assessment Years: 2012-13 & 2018-19 Deputy Commissioner Of Income Tax, Help Line Motor Finance, Central Circle – 2, Vs. No.1, Tam Complex, Nrmp Street, Trichy Covai Road, Karur – 639 002. [Pan:Aaffh 3971 E] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Ms.E.Pavuna Sundari, Cit प्रत्यथी की ओर से/Respondent By : Shri.R.Venkata Raman, Ca & Shri.R.S.Lakshmi Narayana, Advocate सुनवाई की तारीख/Date Of Hearing : 18.06.2025 घोर्णा की तारीख/Date Of Pronouncement : 06.08.2025

For Appellant: Ms.E.Pavuna Sundari, CITFor Respondent: Shri.R.Venkata Raman, CA &
Section 132Section 143(3)

आयकर अपीलीय अधिकरण, ‘ए’ न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI श्री जॉजज जॉजज के, उपाध्यक्ष

Deputy Commissioner of Income Tax, Central Circle-2, Trichy vs. Help Line Motor Finance, Karur

In the result, the appeals of the Revenue in ITA Nos

ITA 622/CHNY/2025[2012-13]Status: DisposedITAT Chennai06 Aug 2025AY 2012-13

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.:656 To 658/Chny/2025 धनिाजरण वर्ज / Assessment Years: 2012-13, 2015-16 & 2018-19 Deputy Commissioner Of Income Tax, No.1 Auto Finance, Central Circle – 2, Vs. No.1, Tam Complex, Nrmp Street, Trichy Covai Road, Karur – 639 002. [Pan:Aahfn 3793 J] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) आयकर अपील सं./Ita Nos.:622 & 633/Chny/2025 धनिाजरण वर्ज / Assessment Years: 2012-13 & 2018-19 Deputy Commissioner Of Income Tax, Help Line Motor Finance, Central Circle – 2, Vs. No.1, Tam Complex, Nrmp Street, Trichy Covai Road, Karur – 639 002. [Pan:Aaffh 3971 E] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Ms.E.Pavuna Sundari, Cit प्रत्यथी की ओर से/Respondent By : Shri.R.Venkata Raman, Ca & Shri.R.S.Lakshmi Narayana, Advocate सुनवाई की तारीख/Date Of Hearing : 18.06.2025 घोर्णा की तारीख/Date Of Pronouncement : 06.08.2025

For Appellant: Ms.E.Pavuna Sundari, CITFor Respondent: Shri.R.Venkata Raman, CA &
Section 132Section 143(3)

आयकर अपीलीय अधिकरण, ‘ए’ न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI श्री जॉजज जॉजज के, उपाध्यक्ष

Albert Joseph Rozario, Mumbai vs. ITO, Int. Tax, Circle 4(1)(1), Mumbai

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 1168/MUM/2025[2018-19]Status: DisposedITAT Mumbai22 Jul 2025AY 2018-19

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2018-19 Albert Joseph Rozario, Ito, (Int. Tax), Circle-4(1)(1), B-311, 5Th Wing, Room No. 629, 6Th Floor, Inlaks Park, Vs. Kautilya Bhavan, Yari Road, Versova, C-41 To C-43, G Block, Andheri West, Bandra Kurla Complex, Mumbai-400058 Bandra East, Pan : Afvpr6139P Mumbai-400051 (Appellant) (Respondent) For Assessee : Shri Dharan Gandhi For Revenue : Shri Sridhar G. Menon, Sr.Dr Date Of Hearing : 01-05-2025 Date Of Pronouncement : 22-07-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Final Assessment Order Passed By The Assessing Officer U/S 147 R/W 144C(13) Of The Act Dt. 30-12-2024, Consequent To The Directions Given By The Ld. Drp-1, Mumbai-3, U/S 144C(5) Of The Act, Dated 30-11-2024 Pertaining To Assessment Year (Ay.) 2018-19. 2. Briefly The Facts Of The Case Are That Basis Information Available Through The Insight Portal That The Assessee Had Purchased Immoveable Properties Amounting To Rs. 8,31,45,549/- & Has Received Interest

For Appellant: Shri Dharan GandhiFor Respondent: Shri Sridhar G. Menon, Sr.DR
Section 144C(1)Section 144C(5)Section 147Section 148Section 148ASection 56(2)(x)Section 69

vide its order u/s 144C(5) dated 30/11/2024 directed the AO that the assessment in assessee‟s case be rendered as a protective assessment while the assessment of Mrs. Cecilia Rozario remains substantive. As per the DRP, this will prevent double taxation on the same income while reserving the option

Abrar Beg Mirza, Khargone vs. Income Tax Officer, Khargone

In the result, the appeal of the assessee is allowed for

ITA 50/IND/2025[2015-16]Status: DisposedITAT Indore17 Jul 2025AY 2015-16

Bench: B.M. Biyani & Shri Paresh M Joshiabrar Beg Mirza, Income Tax Officer, बनाम/ 9 Mugal Bakery, Khargone Vs. Industrial Area, Bhadli, Khargone (Pan: Bgcpm9126Q) (Appellant) (Revenue) Assessee By Shri Venus Rawka, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 10.07.2025 Date Of Pronouncement 17.07.2025 आदेश / O R D E R

Section 143(3)Section 246ASection 250Section 253

basis during the A.Y. 2017-18. 2. The Ld. CIT(A) erred in law and facts of the case and failed to consider that protective assessment made by Assessing officer 2 for A.Y. 2015-16 and failed that the same amount shall be assessed

DCIT, Central Circle-1(3), Bengaluru vs. Late Shri V G Siddhartha, Represented by Legal Heir Ms. Malvika Hegde, Bengaluru

In the result the appeal filed by the revenue is hereby dismissed

ITA 2130/BANG/2024[2016-17]Status: DisposedITAT Bangalore16 Jul 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

1459/Bang/2024 Page 18 of 116 made a substantive assessment on one legal heir and protective assessments on the others. 15.4 To buttress the contention the learned AR further placed reliance on the Hon’ble Supreme Court rulings, in the case of Lalji Haridas (1961 43 ITR 387 SC), and contended

DCIT, Central Circle-1(3), Bengaluru vs. Late Shri V G Siddhartha, Represented by Legal Heir Ms. Malvika Hegde, Bengaluru

In the result the appeal filed by the revenue is hereby dismissed

ITA 2129/BANG/2024[2015-16]Status: DisposedITAT Bangalore16 Jul 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

1459/Bang/2024 Page 18 of 116 made a substantive assessment on one legal heir and protective assessments on the others. 15.4 To buttress the contention the learned AR further placed reliance on the Hon’ble Supreme Court rulings, in the case of Lalji Haridas (1961 43 ITR 387 SC), and contended

Mr. Ishaan Hegde L/R of Late Sri. V G Siddhartha, Bangalore vs. The Deputy Commissioner of Incomer Tax, Central Circle-1(3), Bangalore

In the result the appeal filed by the revenue is hereby dismissed

ITA 1457/BANG/2024[2016-17]Status: DisposedITAT Bangalore16 Jul 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

1459/Bang/2024 Page 18 of 116 made a substantive assessment on one legal heir and protective assessments on the others. 15.4 To buttress the contention the learned AR further placed reliance on the Hon’ble Supreme Court rulings, in the case of Lalji Haridas (1961 43 ITR 387 SC), and contended