In the result, the both the appeals of the assessee are allowed for statistical\npurposes as indicated hereinabove\nOrder pronounced in the open court on\n17/01/2025
penalty of Rs.\n203275/- U/s 271(1)(C ).\n5. That further submissions in support of appeal shall be made at the time of hearing.\n6. That appellant craves leave to add, amend or alter all or any grounds of appeal before or at the\ntime of hearing.\nGROUNDS OF APPEAL\n1. That order of Learned Assessing Authority