A search took place on the assessee’s son wherein certain addition was made in the assessment pursuant to search. On appeal, the Tribunal held that the such addition should have instead been made in the hands of the assessee since the property was held in her name. Proceedings were then initiated under section 158BD in the hands of the assessee and the addition was made therein. The assessee raised an objection, for the first time before the CIT(A), that no separate reasons were recorded by the AO while initiating the proceedings against the assessee under 158BD. Held that non-recording of reasons by the AO in the proceedings against the assessee were not required as the Tribunal had already recorded such reasons while adjudicating on the appeal of the assessee’s son. Further held that once the issue of non-recording of reasons was not agitated before the AO, the same could not have been agitated for the first time before the CIT(A). (BP. 01/04/1995 to 13/09/2001)