Held, that the substantive addition having been confirmed in the hands of the B group would ipso facto make the protective addition in the hands of the assessee unsustainable. Merely because the rate of commission determined by the Tribunal at lower rate was not acceptable to the Revenue that would not be ground for protracted litigation in the case of assessee in whose case the additions were made only on protective basis.  (AY.2008-09, 2009-10)