2. The brief facts of the case are that the assessment was completed under section 143(3) of the Act by the National e-Assessment Centre, Delhi on 09/04/2021 and addition was made related to duty draw back not shown in the return of income amount to Rs.12,547/-. The Ld. PCIT by invoking provisions of section 263 issued notice to the assessee by treating this assessment order as erroneous and prejudicial to the interest of the revenue. The 5 points was asked to explain by the Ld.PCIT in his impugned notice. But finally, related to two points for claiming of depreciation on rented property and the expenses related to excise duty, GST expenses and sales-tax expenses amount to Rs.11,54,204.12 was treated as erroneous and prejudicial to the interest of the revenue, which was not considered by the Ld.AO, by invoking provisions of section 263 of the Act. The aggrieved assessee filed an appeal before us by challenging the revisional order.

3. The Ld.AR argued and filed a paper book spanning pages 1 to 467, which is kept on record. The Ld.AR argued that the property was given on rent and the said rent was declared as business income and accordingly, the depreciation was claimed. During the a