Section 68 Addition of ₹3 Cr Deleted – Loan from RBI-Registered NBFC Held Genuine

Matrix Clothing Pvt. Ltd. Vs ACIT (ITAT Delhi) TPO’s CUP Theory Collapses — ITAT Deletes SBLC TP Adjustment; Corporate Guarantee ≠ Bank Guarantee- Loan from RBI-Registered NBFC Is Genuine — Section 68 Addition of ₹3 Cr Deleted Delhi ITAT adjudicated multiple TP and non-TP issues arising from DRP-based assessments u/s 143(3) r.w.s. 144C. 1. TP Adjustment on SBLC / Corporate Guarantee — Deleted TPO assumed that Assessee did not recover SBLC charges from its AE and applied CUP using bank-guarantee commission rates. ITAT found that Assessee had recovered ₹99.10 lakh on cost-to-cost ...