Atul Traders vs Income Tax Officer on 14 July, 2005
12. Learned counsel for the petitioner in support of his contention referred to the case of AB. Parikh v. ITO . In the aforesaid decision, the learned single Judge has taken the view that when
the entity in question are independent legal/juristic person, then notice should be given under Expln. 3 of Section 153 of the Act. Relevant portion of the judgment reads :