protective assessment ?

Protective assessment is resorted to by the Income-tax authorities where there is an anamalous position with regard to the person in whose hands a particular income is assessable. In order to protect their interest, they make two assessments on the same income on two different entities. Ultimately when it is settled, one would get eliminated. However, in a case where the department holds an assessment as protective, then automatically they should withhold enforcement of collection untill the issue is resolved in appeal. They would, however insist on tax payment in respect of the entity where they regard the assessment as substantive