Section 68, 92CA of Income Tax Act, 1961—In the instant case, in ground no. 1 assessee has challenged the addition of Rs. 80,000/-sustained by CIT(A) regarding to small trade deposit taken from small dealers, we find that the loan amount of Rs. 80,000/- constitutes deposits of Rs. 10,000/- each from 5 parties and Rs. 5,000/- each from 6 parties. The payments were received through cheques and were part of the trade deposits.

Held that— 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 ground no. 3 the assessee has challenged the addition for Upward Adjustment of Rs. 17,77,393/- 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 of Rs. 17,73,393/- made u/s 92CA(3) of the Act and allow. Ground no. 3 raised by the assessee.[SYMPHONY LTD. SYMPHONY VERSUS DY. COMMISSIONER OF INCOME TAX, CIRCLE-4 (1) (1) ‘B’ WING, AHMEDABAD] [2019] 17 ITCD Online (27) [ ITAT AHMEDABAD]