2023 (4) TMI 744

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....inst the order passed by the Commissioner of Income-Tax (Appeals), National Faceless Appeal Center (NFAC), Delhi, dated 21.11.2022, which in turn arises from the order passed by the A.O under Sec. 154 of the Income-tax Act, 1961 (in short 'the Act') dated 18.07.2018 for the assessment year 2010-11. The assessee has assailed the impugned order on the following grounds of appeal: "1. The order of ....

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....Act wherein his claim for depreciation of Rs.4,67,247/- was not considered. 3. Aggrieved the assessee had filed a rectification application u/s.154 of the Act on 31.01.2018. As the rectification application was filed by the assessee beyond the stipulated time period of four years from the end of the financial year in which the order sought to be amended was passed, therefore, on the said count it....

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....apse of four years from the end of the financial year in which intimation u/s.143(1) of the Act dated 13.12.2010 was issued by the A.O. As the aforesaid application was filed by the assessee u/s.154 of the Act beyond the stipulated time period as provided in sub-section (7) of Section 154 of the Act, therefore, in my considered view the same was rightly held by the A.O as not maintainable. For the....