Held that the additions made in the hands of the beneficiary company in various assessment years were on substantive basis, as affirmed by the Commissioner (Appeals) whereas the additions made on the assessee-company were on protective basis, and were deleted on the ground that the substantive additions were sustained. Accordingly, the addition made on protective basis in the hands of Suresh Kumar Agarwal  could also not be sustained. The Assessing Officer was directed to delete the addition.(AY. 2011-12 to 2014-15)