Chandrawati Devi Vs ITO (ITAT Agra)
The Income Tax Appellate Tribunal (ITAT), Agra Bench, disposed of two connected appeals filed by the assessee against the order of the Commissioner of Income-tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, dated 11.12.2025 for Assessment Years (AYs) 2010-11 and 2012-13. As both appeals involved identical issues, the Tribunal heard them together and treated the appeal for AY 2010-11 as the lead case.
During the hearing, the assessee submitted that the assessment order had been passed in the name of Chandrawati Devi by treating her as the legal heir after the death of the original assessee, Late Shri Mangal Sen. It was contended that the Assessing Officer brought the legal heir on record solely for completing the assessment and passed the assessment order accordingly. The assessee thereafter preferred an appeal before the CIT(A), which was dismissed due to non-compliance. Aggrieved by that order, the assessee approached the Tribunal.
The assessee further argued that the assessment was not legally sustainable since it had been framed merely by treating the appellant as a legal heir. Reliance was placed on the earlier decision of the coordinate bench in Pradeep Jain, Legal Heir of Late Shri Jay Narayan (ITA Nos. 334 to 338/Agr/2024 dated 06.02.2025), where similar facts had been considered.
