The assessee has to verify what is the date of the notice . In case the notice is dated after 1, -4 -2021 the Assessing officer has to follow the law as mandated under section 148A of the Act . .ie. Conducting inquiry , providing opportunity before issue of notice under section 148 of the Act. If the notice refers the section 148 then the assessee can write to the issuing authority to drop the proceedings as it is not in accordance with law and hence bad in law . If no response is received within reasonable time , the assessee may challenge the notice by filing the writ petition . Bombay High court and other High Courts have admitted number of petitions on the issue of notice without following the due process of law and stayed the proceedings . Refer Tata Communications Transformation services Ltd v. CIT www.itatonline .org The assessee has to verify what is the date of the notice . In case the notice is dated after 1, -4 -2021 the Assessing officer has to follow the law as mandated under section 148A of the Act . .ie. Conducting inquiry , providing opportunity before issue of notice under section 148 of the Act. If the notice refers the section 148 then the assessee can write to the issuing authority to drop the proceedings as it is not in accordance with law and hence bad in law . If no response is received within reasonable time , the assessee may challenge the notice by filing the writ petition . Bombay High court and other High Courts have admitted number of petitions on the issue of notice without following the due process of law and stayed the proceedings . Refer Tata Communications Transformation services Ltd v. CIT www.itatonline .org

Tata Communications Transformation Services Limited
In case the assessee is not desires to file writ petition the assessee may file the return under protest , request for recorded reason , file objections after receipt of recorded reasons and after assessment the follow the normal course of appeal .

In case the notice is dated on or before 31 -3 -2021 , the assessee may have to file the return under protest and request for recorded reasons . When assesesee receives the recorded reason the assessee has to file the detailed reply , wherein the assessee can request for dropping of the reassessment proceedings . In case the order is passed by the assessing Officer disposing the objection , the assessee may file writ petition against the order disposing of objections . By following the guidelines referred by supreme Court GKN Driveshafts (India) Ltd v. DCIT (2003) 259 ITR 19 (SC)
and Bombay High Court in Asian Paint Ltd. v. Dy. CIT (2008) 296 ITR 90 (Bom.)(HC), Allana Cold Storage Ltd v. ITO (2006) 287 ITR 1 (Bom.) (HC)
. In case the quantum is negligible the assessee may follow the normal assessment procedure and appeal may be filed after receipt of the order .

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