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-guaran

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