Appeal allowed on procedural grounds, case remanded for comprehensive review.

The appeal was filed against the order passed by the National Faceless Appeal Centre, Delhi for A.Y. 2014-15. The Assessing Officer dismissed the appeal as time-barred due to a delay of 384 days. The ITAT found discrepancies in the assessment order and directed the CIT (A) to reexamine the case, considering the issues related to the rectification order, capitalization of pre-construction interest, depreciation, and the credit of TDS. The appeal was allowed for statistical purposes, and the case was remanded back to the CIT (A) for a comprehensive review and decision on all relevant aspects.

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Issues:
1. Delay in filing appeal u/s 246A of the Act.
2. Rectification order passed by the Assessing Officer.
3. Capitalization of pre-construction interest.
4. Depreciation on capitalization of pre-construction interest.
5. Credit of TDS not allowed.

Issue 1 - Delay in filing appeal u/s 246A of the Act:
The appeal was filed against the order passed by the National Faceless Appeal Centre, Delhi for A.Y. 2014-15. The Assessing Officer held that the appeal was delayed by 384 days and dismissed it as time-barred. The appellant contended that the appeal was filed within 30 days of the service of the notice of demand, as prescribed under Section 249(2)(c) of the Act. The appellant argued that the order under Section 154 of the Act was not made available until 28 February 2019, and hence, the appeal was filed within the stipulated time. The ITAT found that the CIT (A) did not consider all relevant details and columns in the appeal form, leading to the incorrect conclusion of delay. The ITAT set aside the appeal back to the CIT (A) for a thorough examination of the service of the order, the reasons for any delay, and to provide the appellant with an opportunity to clarify the timely filing of the appeal.

Issue 2 - Rectification order passed by the Assessing Officer:
The Assessing Officer passed a rectification order proposing disallowance of interest expenditure and property tax. The appellant objected to this order, leading to the Assessing Officer passing a rectification order disallowing standard deduction and pre-construction interest cost. The CIT (A) noted a delay in filing the appeal electronically and dismissed it as time-barred. The ITAT found discrepancies in the assessment order and the appellant's contentions regarding the treatment of rental income and disallowances. The ITAT directed the CIT (A) to reexamine the case and decide on the merits after addressing the issues related to the rectification order.

Issue 3 & 4 - Capitalization of pre-construction interest and Depreciation:
The appellant argued for the capitalization of pre-construction interest and depreciation on the same, which the Assessing Officer had not allowed. The ITAT directed the CIT (A) to consider these arguments along with the rectification order issues and decide on the merits in accordance with the law.

Issue 5 - Credit of TDS not allowed:
The appellant claimed credit for TDS in the return of income but the Assessing Officer failed to allow it. The ITAT did not specifically address this issue in the judgment as it was not required to be adjudicated upon due to the decision made on the first issue. The appeal of the appellant was allowed for statistical purposes, and the case was remanded back to the CIT (A) for a comprehensive review and decision on all relevant aspects.

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