In the result, this appeal of assessee is allowed

Bench: Shri Pawan Singh & Shri Khettra Mohan Roy(Physical Hearing) Fattesing Punaji Dhabre Pcit – 2, Nagpur Plot No. 132, Chandan Nagar, Post Vs Aayakar Bhawan, Civil Lines, Hanuman Nagar, Nagpur, Maharashtra – 440001. Maharashtra – 440009. [Pan: Bacpd6505Q] Appellant / Assessee Respondent / Revenue Assessee By Shri Madhav Vichare, Ca Revenue By Shri Pankaj Kumar, Cit–Dr Date Of Hearing 17.02.2026 Date Of Pronouncement 24.02.2026 Order Under Section 254(1) Of Income Tax Act

198 TTJ 0310 (Visakha)” 7. On the other hand, the learned Commissioner of Income Tax – Departmental Representative (ld. CIT–DR) for the Revenue, on the plea of condonation of delay would submit that assessee has not explained the delay properly. The assessee is relying upon self–serving story and delay may not be condoned. On the admission of additional ground