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TMI Blog2020 (1) TMI 1061X X X X Extracts X X X X X X X X Extracts X X X X ..... the notice issued u/s 148 including the limitation and also by contending that it is based on change of opinion, but these contentions cannot be considered at this stage now, since the petitioner is bound to give objections to the reasons for reopening and thereafter, AO has to pass a reasoned order, as observed by the Apex Court in GKN Driveshafts (India) Ltd. case [ 2002 (11) TMI 7 - SUPREME COU ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the Income Tax Act, 1961, proposing to reopen the Assessment relevant to Assessment Years 1999-2000, 2001-2002 and 2002-2003, by contending that the petitioner's income assessable/chargeable to tax has escaped assessment within the meaning of Section 147 of the Income Tax Act, 1961. 2. The contentions of the petitioner in these writ petitions questioning the impugned notice issued under Se ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... objections to the reasons for reopening. He further submitted that the petitioner was already furnished with the reasons for reopening and therefore, it is for them to make the objections and thereafter, to allow the Assessing Officer to pass orders on such objections, as observed in "GKN Driveshafts (India) Ltd. case (supra). 5. Therefore, the contention of the learned senior standing couns ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at this stage can be maintained any further. Therefore, without expressing any view on the merits of the contentions raised by the petitioner against the impugned notice, these writ petitions are disposed of, by granting liberty to the petitioner to give objections to the reasons for reopening, within a period of four weeks from the date of receipt of a copy of this order. On receipt of such obje ..... X X X X Extracts X X X X X X X X Extracts X X X X
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