Tribunal held  that the Assessing Officer had admitted in the body of the order itself that the seized documents pertained to G and not to the assessee who was a director in G. The protective assessment was made on the ground that the assessment proceedings were getting time barred by limitation. Since the substantive addition was deleted in the hands of G, the liability under section 179 on the assessee, in the capacity of the director of G also stood absolved. Nowhere had the Commissioner (Appeals) confirmed the protective addition on the ground that the amount was paid by the assessee. Thus, the protective addition under section 179 stood nullified as the substantive addition stood deleted in the hands of G. Further, the arbitral tribunal had negated the accusations of fraud, corrupt practices, collusion, etc., against G and had also held that the accusations were purely and solely based on the Shunglu Committee report, the CAG report and the FIR lodged by the CBI which remained unsubstantiated and unproven. The arbitral award was confirmed by the High Court. Thus the protective addition in the hands of the assessee was not sustainable.( AY. 2011-12)