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Section 68 Addition of ₹3 Cr Deleted – Loan from RBI-Registered NBFC Held Genuine
Case Law Details
- Case Name
- Matrix Clothing Pvt. Ltd. Vs ACIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2017-18
- Courts
- All ITAT, ITAT Delhi
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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 ...
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