ORDER

PER KESHAV DUBEY, JUDICIAL MEMBER:

This appeal at the instance of the Revenue is directed against the order of ld. Commissioner of Income Tax (Appeals), Bengaluru-12, Bengaluru dated 07.01.2025 vide DIN & Order No. ITBA/APL/S/250/2024-25/1071941288(1) passed u/s. 250 of the Income Tax Act, 1961 (in short “the Act”) for the AY 2013-14. The assessee has also filed a cross objection in CO No. 24/BANG/2025 against the said appeal of the Revenue in ITA No.1317/BANG/2025.

2. The Revenue has raised the following Grounds of appeal: -

3. At the outset, the ld. DR submitted that there is a delay of 65 days in filing the appeal before this Tribunal by the Revenue. Before us, the ld. D.R. drew our attention to a letter dated 15.12.2025 stating therein the cause for delay, which is reproduced below for ease of reference and convenience:-

4. On going through the above letter, we observed that the main cause cited for delay was solely attributable on account of unintentional and unavoidable reasons and in lieu of assessment proceedings getting time barred on 31.3.2025 and reopening proceedings getting time barred on 30.6.2025, and therefore the appeal could not be filed within the prescribed per