Against an order of the High Court dismissing the assessee’s writ petition against notice under section 148 of the Income-tax Act, 1961, but directing the Department to provide the assessee a copy of the reasons based on which notice under section 148 was issued, the assessee filed a petition for special leave to appeal to the Supreme Court. Dismissing the petition the Court held that the order of the High Court was a non-speaking and cryptic order, did not issue notice on the special leave petition but left it open to the assessee to file a return of income under protest within one month, without prejudice to its rights and contentions, and ask for the reasons for issue of notice under section 147 of the Act. The court directed that procedure as prescribed in GKN  Driveshafts (India) Ltd. v. ITO (2003) 259 ITR 19 (SC)  would be followed by the Assessing Officer. In the case of an adverse order, it would be open to the assessee to challenge it.