The appeal of the assessee is allowed, whereas\nappeal of the revenue is dismissed
penalty\nproceedings are also unwarranted and deserve to be quashed.\n10. Without prejudice to the above your assessee craves leave to add, amend,\nalter, vary or withdraw all or any grounds of appeal on or before the hearing of\nappeal.\"\n4. First, we shall adjudicate revenue's appeal in ITA No. 682/Rjt/2025. The\nfacts necessary for disposal of the revenue