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2019 (9) TMI 949 - ITAT AHMEDABADAddition u/s 68 - small trade deposit taken from small dealers - HELD THAT:- Loan amount of ₹ 80,000/- constitutes deposits of ₹ 10,000/- each from 5 parties and ₹ 5,000/- each from 6 parties. The payments were received through cheques and were part of the trade deposits. Looking to the turn-over of the assessee which stood at ₹ 225.9. crores and the profit before the tax at ₹ 57.87 crores, we do not find any reason to doubt the genuineness of the small trade deposits receivedin normal course of business and thus direct the Assessing Officer to delete the same. In the result ground no. 2 of the assessee-appeal stands allowed and additions u/s 68 is deleted. Addition u/s 92CA(3) - Upward Adjustment for the notional interest calculated on the extended credit period provided to the Associate Enterprise (IMPCO) (Mexico) - HELD THAT:- We are of the view that since that the extended credit period provided by the assessee has been adjusted by the higher sale price charged to the AE and such transactions of providing extended credit period for more than 90 days or above cannot be considered as a separate International transaction, do not call for and any Upward Adjustment. We accordingly direct the AO to delete the additions for Upward Adjustment made u/s 92CA(3)
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