The AO initiated re-assessment proceedings on the ground that the assessee has purchased immovable property. However, in fact the assessee alongwith his co-owners had sold their ancestral land. On a writ petition filed with the High Court, it was held that:

The Department has proceeded to initiate re-opening proceedings on wrong assumption of facts. In fact the Revenue has admitted in the Affidavit filed by it that due to typographical error/ oversight the sale of land has been typed as purchase of land. It was held that this is not permissible in law and the reasons for re-opening as to be read as they were recorded by the AO and no substitution or deletion is permissible. The reasons recorded for re-opening should be clear and unambiguous and cannot be supplemented by filing an affidavit or oral submissions. Thus, the notice and the order passed thereof was quashed and set-aside with a liberty to the Revenue to initiate fresh proceedings in accordance with law.  (AY. 2017 -18 )