In the result, appeals of the assessee for all the three AYs 2012-13,
Bench: Ms. Astha Chandra & Shree G.D. Padmahshali
penalty u/s 271(1)(c). 8. The appellant craves, leave to add, alter all, or any of the grounds of appeal on or before hearing.” 4. Vide application dated 23.04.2024 the assessee has requested for admission of additional legal grounds not expressly taken before the Ld. CIT(A) but were raised in written submissions filed before him. It is stated