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TMI Blog2024 (12) TMI 644X X X X Extracts X X X X X X X X Extracts X X X X ..... Sh. Dharamvir Singh, CIT(DR) ORDER PER YOGESH KUMAR U.S., JM This appeal is filed by the Assessee for the Assessment Year 2016-17 against the order of the Commissioner of Income Tax (Appeal), ("Ld. CIT (A) for short)-Delhi 44 dated 09/03/2023. 2. The grounds of Appeal are as under: - "1. That on the facts and circumstances of the case and in law, the Assessing Officer and the Learned Commiss ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essee s stand. 4. The appellant craves leave to add, alter, modify, vary or delete any ground of appeal before or during the appellate proceedings." 3. Brief facts of the case are that, the Assessee filed return of income of Rs. 12,90,45,370/-. The case of the Assessee was selected for scrutiny. In view of international transaction with AE a reference was made to TPO u/s 92CA(1) of the Income T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... suo-moto adjustment made by the Assessee based on the actual cost incurred by the Assessee. Thus, sought for allowing the Appeal. 5. Per contra, the Ld. Departmental Representative relying on the orders of the Lower Authorities, sought for dismissal of the Appeal. 6. We have heard both the parties and perused the material available on record. The only dispute between the Assessee and the Departm ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... made addition of Rs. 4,49,084/-. 7. Considering the fact that the Assessee has made voluntary adjustment of 0.94% which is claimed be made based on the actual cost incurred by the Assessee, without going into the issue raised in Ground No. 1 and 3, considering the smallness of the amount, with an intention to put an end litigation, we delete the addition made by the A.O. which has confirmed by th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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