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Ground of appeal of the assessee is that the learned CIT(A) grossly erred in holding that the protective addition of Rs. 35,85,00,000 in the hands of the appellant was in line with the provisions of s. 179 of the IT Act, 1961.

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Sec. 4, 179 & 292C of Income-tax Act, 1961— Income from undisclosed sources—Protective addition in the hands of the assessee does not have any feet to stand on, since, the protective addition was upheld by CIT(A) solely for the purposes of s. 179 and since the substantive addition has been deleted, the basis for protective addition also goes, therefore, the protective addition in the hands of the assessee was quashed. - BINU NANU V/s DY. CIT - [2020] 206 TTJ 854 (ITAT-DELHI)