14 - served on the appellant on 28/04/2014 - HELD THAT:- We find no merit in Revenue’s instant arguments. The facts remains the CIT(A) made tremendous efforts by way of various correspondence(s) to get all the relevant material on record as to whether the impugned assessment had been framed within the statutory time limit up to 31.03.2014 or not. It has come on record that the assessing authority had also failed to indicate any material on record that the relevant computation had been uploaded even on the department’s portal. We therefore hold that the CIT(A) has rightly quashed impugned assessment not framed within the time limitation prescribed.
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Hon’ble jurisdictional high court’s decision CIT vs. Subrata Roy [2014 (7) TMI 42 - CALCUTTA HIGH COURT] involves a case where the Revenue had filed sufficient proof before their lordships that the Assessing Officer had framed the assessment in issue within the time period prescribed as against the facts of the instant case. Distinguis

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