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2026 Supreme(Online)(ITAT) 6826

INCOME TAX APPELLATE TRIBUNAL (BANGALORE BENCH)
PRASHANT MAHARISHI, Vice-President, KESHAV DUBEY, Judicial Member
DCIT/ACIT Central Circle-2(2)(1) – Appellant
Versus
CSG Systems International (India) Pvt. Ltd. – Respondent


Advocates:
For the Appellants/Petitioners: Sri Aliasgar Rampurawala & Shri Sumeet M, A.Rs
For the Respondents: Sri N. Balusamy, D.R.

Table of Content
1. appeal and cross-objection details introduced (Para 1 , 2)
2. revenue's appeal delay condoned (Para 3 , 4)
3. assessee's cross-objection delay condoned (Para 5 , 6 , 7)
4. additional legal grounds admitted (Para 8 , 9)
5. draft order treated as final due to demand/penalty (Para 10 , 11 , 12 , 13 , 14)
6. revenue appeal dismissed; assessee co allowed (Para 15)

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

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