Re: Protective v/a substantive
We have won the search case u/s 132 at ITAT forum,now IT deptt preferred appeal in Delhi High court
In above matter Addition made on Substantive basis in Company A disputed tax demand exceeding 5 crore say 7 crore ,hence not eligible for Scheme
Whereas in above AO made addition in B & C each 3.5 crore on Protective basis
Can we go in scheme on protective basis ,ignoring the substantive basis ?
It is recommended not to go for VSV. However, even if opted for VSV the same will not be eligible for set off against addition made on substantive basis in Company A.
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