Reassessment notice procedure under Section 147: reasons must be furnished, rights preserved, and return may be filed under protest.

In reassessment proceedings, the assessing officer must give reasons for issuing notice under Section 147 and follow the procedural safeguards laid down in GKM Driveshafts (India) Ltd. v. ITO; any adverse order remains open to challenge by the taxpayer. The Supreme Court dismissed the special leave petition despite noting the impugned order was non-speaking and cryptic, while leaving all contentions open. It also permitted the taxpayer to file the return of income under protest within one month, without prejudice to rights and contentions, so tax compliance can proceed while the challenge is preserved.

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Outcome: Special leave petition dismissed; the Court declined to issue notice and left it open to the petitioner to pursue the statutory course relating to reopening under Section 147 of the Income-tax Act, 1961.

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