It often happens that assessing officer issues notice u/s 148 for reassessment . These notices for reassessment , almost always, do not contain any reasons for reopening of assessment , as noted by the A.O before issue of notice for reassessment u/s 148. Since Income Tax Act is silent on the question whether the reasons to believe for issue of notice u/s 148 be given to assessee and if given what procedure has to be followed , the matter reached Supreme Court in GKN Driveshafts (India) Ltd. v. ITO reported in  259 ITR 19. in which the Hon’ble Supreme Court set clear procedure to be adopted on issue of notice u/s 148 . This site has published an article What Should You Do On Receipt Of Reassessment Notice? When Supreme Court decides an issue , it is incumbent upon all to follow the ruling without being provoked , as the ruling becomes law of land.