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(iii) That the appellant craves for the permission to add, delete or amend the ground of appeal before or at the time of hearing of appeal."

3. The brief facts of the case are as under:-

Survey operations u/s. 133A were conducted on the business premises of the assessee at Bahadurgarh on 7.2.2011. On perusal of the records / data, the Assessing Officer noted that TDS has not been made on the payments made to some parties on account of contract work done by them. The assessee submitted to the Assessing Officer that they have received lower/ non deduction of tax certificates issued by IT authorities and followed the same while deducting the TDS. The Assessing Officer noted from the perusal of such certificates that they have been issued by the officers of the Department in the name of Parle Biscuits Pvt. Ltd., Mumbai and not in the name of Parle Biscuits Pvt. Ltd., Bahadurgarh in respect of some parties noted in page 2 of the impugned order. When confronted, the assessee submitted that Mumbai is their head office and ITA NO. 100/Del/2012 therefore credit of lower deduction tax certificates has been issued to the deductee parties while making payment to them. The Assessing Officer did not accede to the contention of the assessee and raised a demand of ` 67,38,214/- including interest u/s. 201(1) and 201(1A) of the Act.