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In the result, the assessee's appeal is allowed
Bench: Shri R. K. Panda & Shri Vinay Bhamore
section 271(1)(c) of the Act, whereas the penalty has ultimately been imposed for the other limb. The penalty order be treated as null and void. The Appellant be granted just and proper relief in this respect. 3. The Appellant prays to be allowed to add, amend, modify, rectify, delete, and raise any grounds of appeal at the time