2022 (10) TMI 377

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..... inclined to issue notice in the present special leave petition and leave it open to the petitioner to file return of income under protest within one month, without prejudice to the rights and contentions, and ask for the reasons for issue of notice under Section 147 of the Income Tax Act, 1961. The procedure as prescribed in GKM Driveshafts (India) Ltd. [ 2002 (11) TMI 7 - SUPREME COURT ] would b .....

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..... in one month, without prejudice to the rights and contentions, and ask for the reasons for issue of notice under Section 147 of the Income Tax Act, 1961. The procedure as prescribed in GKM Driveshafts (India) Ltd. Vs. ITO [reported in (2003) 259 ITR 19 , would be followed by the assessing officer. In case of an adverse order, it will be open to the petitioner to challenge the same. All con .....

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