ITAT Deletes Addition on Bank Guarantee Classification Dispute, Rejects AO's 2.22% Rate for 0.94% Actual Cost Adjustment.

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....The ITAT deleted the addition made by the Assessing Officer (AO) and upheld by the Commissioner of Income Tax (Appeals) [CIT(A)] regarding the adjustment u/s 92CA(3) of the Income Tax Act. The issue pertained to the treatment of a guarantee/standby letter of credit issued by Standard Chartered Bank, New Delhi, as an international transaction. The CIT(A) had upheld the AO's action of adopting an average rate of 2.22% based on rates of nine banks for making the adjustment u/s 92CA(3), instead of the suo-moto adjustment made by the assessee based on the actual cost incurred. The ITAT, considering the voluntary adjustment of 0.94% made by the assessee based on the actual amount paid to Standard Chartered Bank for the bank guarantee, and the smallness of the amount involved, deleted the addition made by the AO to put an end to the litigation.....