In the result, the appeal of the assessee is allowed
Bench: Sh. N. K. Sainiita No. 123/Pat./2017 : Asstt. Year : 2010-11 Rajeev Ranjan, Vs Income Tax Officer, S/O Sita Ram Singh, Garhpar, Ward-2(3), Bihar Sharif, Nalanda-803101 Bihar Sharif (Appellant) (Respondent) Pan No. Agcpr5450R Assessee By : Sh. A. K. Rastogi & Sh. Rakesh Kumar, Advs. Revenue By : Sh. Abhay Kumar, Sr. Dr Date Of Hearing : 14.03.2018 Date Of Pronouncement : 16 .03.2018 Order This Is An Appeal By The Assessee Against The Order Dated 30.06.2017 Of Ld. Cit(A)-1, Patna.
14A of the Act.” 10. From the aforesaid reasons recorded, it is clear that the AO initiated the proceedings u/s 147 of the Act only on the basis of the assessment records wherein it was mentioned that the assessee had purchased land. Now question arises as to whether that issue was examined by the AO during the course of original